Yes, as long as the provision of services does not involve an entity blocked pursuant to E.O. 14024 and is not otherwise prohibited by OFAC sanctions. The price cap policy does not authorize transactions otherwise prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR), including transactions involving any person blocked pursuant to the RuHSR, unless separately authorized. For more information on the price cap policy, please see OFAC's price cap policy guidance.

See FAQ 1216 for more information on The Determination Pursuant to Sections 1(a)(ii), 1(b), and 5 of E.O. 14071, Prohibition on Petroleum Services. See FAQs 1213 and 1214 for more information on the January 2025 Energy Sector Determination, issued pursuant to E.O. 14024.

In line with G7 efforts to reduce Russian revenues from energy, on January 10, 2025, Treasury issued a determination pursuant to Executive Order (E.O.) 14071 prohibiting petroleum services to Russia. See The Determination Pursuant to Sections 1(a)(ii), 1(b), and 5 of E.O. 14071, Prohibition on Petroleum Services ("the Petroleum Services Determination"). This determination prohibits the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, to any person located in the Russian Federation of petroleum services. The Petroleum Services Determination will take effect at 12:01 a.m. eastern standard time on February 27, 2025.  See FAQ 1217 for additional information.

OFAC expects to issue regulations defining petroleum services to include services related to the exploration, drilling, well completion, production, refining, processing, storage, maintenance, transportation, purchase, acquisition, testing, inspection, transfer, sale, trade, distribution, or marketing of petroleum, including crude oil and petroleum products, as well as any activities that contribute to Russia’s ability to develop its domestic petroleum resources, or the maintenance or expansion of Russia’s domestic production and refining. This would include services related to natural gas as a byproduct of oil production in Russia.

Concurrently, OFAC issued GL 121 to authorize any petroleum services that would otherwise be prohibited by the Petroleum Services Determination related to the operations of the Caspian Pipeline Consortium, Sakhalin II, or Tengizchevroil, (2) any petroleum services related to isotopes derived from petroleum manufacturing that are used for medical, agricultural, or environmental purposes, such as Carbon-13; (3) certain covered services related to the maritime transport of crude oil and petroleum products of Russian Federation origin purchased at or below the relevant price cap; and (4) any service in connection with the wind down or divestiture of an entity located in the Russian Federation that is not owned or controlled, directly or indirectly, by a Russian person. See FAQ 1217 for additional information related to price cap related exclusions of the Petroleum Services Determination.  

GL 26 applies to transactions involving specified persons identified in the Annex to GL 26, who are designated under both the URSR and the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR). The purpose of GL 26 is to ensure that transactions authorized or exempt under the RuHSR, including transactions authorized by a general or specific license, that involve those specified persons are also authorized under the URSR, to the extent such transactions are prohibited by Executive Order (E.O.) 13662. However, GL 26 does not authorize any transaction prohibited by a directive issued pursuant to E.O. 13662, as incorporated into sections 589.202 through 589.205 of the URSR, or any transaction involving any person blocked pursuant to the RuHSR or the URSR other than the specified persons, unless separately authorized.

No. On January 10, 2025, the Secretary of the Treasury, in consultation with the Secretary of State, issued a determination pursuant to E.O. 14024 that authorizes the imposition of economic sanctions on any person determined to operate or have operated in the energy sector of the Russian Federation economy. 

A sector determination pursuant to E.O. 14024 exposes persons that operate or have operated in an identified sector to sanctions risk; however, a sector determination does not automatically impose sanctions on all persons who operate or have operated in the sector.

On January 10, 2025, the Secretary of the Treasury, in consultation with the Secretary of State, issued a determination pursuant to E.O. 14024 that authorizes the imposition of economic sanctions on any person determined to operate or have operated in the energy sector of the Russian Federation economy. For purposes of the January 2025 Energy Sector Determination, OFAC anticipates publishing regulations defining the term "energy sector of the Russian Federation economy" to include activities such as the procurement, exploration, extraction, drilling, mining, harvesting, production, refinement, liquefaction, gasification, regasification, conversion, enrichment, fabrication, manufacturing, testing, financing, distribution, purchase or transport to, from, or involving the Russian Federation, of petroleum, including crude oil, lease condensates, unfinished oils, natural gas, liquefied natural gas, natural gas liquids, or petroleum products, or other products capable of producing energy, such as coal, wood, or agricultural products used to manufacture biofuels; the development, production, testing, generation, transmission, financing, or exchange of power, through any means, including nuclear, electrical, thermal, and renewable, to, from, or involving the Russian Federation; and any related activities, including the provision or receipt of goods, services, or technology to, from, or involving the energy sector of the Russian Federation economy.

This definition is similar to the energy sector definition set forth under the Ukraine-/Russia-Related sanctions in 31 CFR 589.311 but includes additional language identifying specific activities and petroleum products, reflecting developments since the Department of the Treasury issued a determination pursuant to section 1(a)(i) of Executive Order 13662 on July 16, 2014. OFAC intends to update the SDN List to reflect whether persons have been designated pursuant to E.O. 14024, E.O. 13662, or both.