The oil price cap is an unusual sanctions instrument. It does not prohibit the trade. It conditions the availability of the services the trade depends on — shipping, insurance, brokering, flagging and financing — on the cargo having been bought at or below a stated price.
Because no service provider can observe the price paid between two foreign counterparties, the regime delegates verification down the chain through attestations. Each participant certifies what it knows to the next. Attestation fraud is the corruption of that mechanism.
How it works
The 2023 maritime oil industry advisory sets out both the intended operation of the attestation model and the ways it is subverted.
The bare attestation. A statement is provided that the cap was respected, with no supporting documentation and no itemisation. The service provider holds a piece of paper. The advisory’s formulation is about itemisation rather than refusal: industry stakeholders using cost-insurance-freight contracts should require an itemised breakdown of all costs to determine the price paid for the oil1 , and the billing of commercially unreasonable or opaque shipping and ancillary costs should be viewed as a sign of potential price cap evasion2 .
Cost inflation. The cap applies to the price of the oil, not to freight, insurance and other ancillary costs. Where those charges are set far above prevailing market rates, value that is really payment for the cargo is relabelled as payment for services. The declared oil price complies; the total does not reflect it.
This is the point at which price cap fraud becomes a species of trade misinvoicing, and the analytical approach is the same: benchmark the components against market rates and ask what the residual is doing.
Attestation laundering. Because attestations are passed along a chain, a false statement at the origin is repeated by intermediaries who genuinely do not know better. Each downstream party has an attestation and has done what the regime asked. The falsity sits at the top of a chain that was designed to distribute the verification burden and instead distributed the ignorance.
Why it sits alongside the other maritime techniques
A cargo that cannot obtain a compliant attestation needs services that do not require one, which means leaving the mainstream shipping, insurance and financing market. That is the same exit that produces unverifiable insurance, rapid reflagging, opaque single-ship ownership and irregular transponder behaviour.
The techniques therefore cluster, and the cluster is more informative than any element of it. The 2023 advisory reflects this by addressing insurance3 , classification4 , AIS behaviour4 and cost itemisation1 in a single document. It is worth noting that the word “attestation” does not appear in the advisory itself; the attestation model is set out in the separate price cap implementation guidance, and this page uses the term as the industry does.
How it is caught
Itemisation testing. A price that cannot be broken into a cargo cost and identified ancillary costs is not testable. The advisory’s remedy is to require an itemised breakdown of all costs1 , and to treat inflation or bundling of shipping and ancillary costs — freight, customs, insurance — as a tactic used to conceal that oil was bought above the cap5 .
Freight benchmarking. Freight and insurance rates are published and comparable. Charges materially above market on a specific route are quantifiable, and the excess over the benchmark is a measure of what has been relabelled.
Documentary escalation. The regime contemplates that a service provider will ask for the underlying documents where something is unclear. A refusal is itself the finding.
Voyage reconstruction. The attestation implies a cargo, a load port and a route. Where the vessel’s actual movements contradict them — an unrecorded transfer, a different load port, a gap covering the loading window — the attestation is inconsistent with what the ship did.
The vessel-level records used for that last check are maintained on the sister vessels site.