Russian-origin barrels via AZ/KZ refinery routing. The pattern Treasury has flagged five times running.

• OFAC Directive 4 under Executive Order 14024 prohibits US persons from engaging in transactions with the Central Bank of Russia. Refined products derived from CBR-financed Russian crude inherit the sanctions exposure, there is no neutralization through intermediate refining.
• G7 price cap (Regulation No 833/2014, as amended) on Russian-origin crude and petroleum products is explicit: re-refining or blending Russian-origin barrels in a third-country refinery does NOT transform the origin status for price-cap purposes. The Commission published this guidance in February 2023; it has been reaffirmed every six months since.
• OFSI General Guidance on the Russia (Sanctions) (EU Exit) Regulations 2019 tracks the same logic. UK persons facilitating origin-laundering face civil monetary penalties + potential criminal referral.
• EU Commission Notice on the implementation of the Russian oil price cap (October 2023) explicitly addresses AZ/KZ refinery routing as a known evasion pattern subject to enforcement.

The point is not that your compliance officer needs to memorize this, the point is that none of the cited “waivers” or “safe harbors” a broker mentions can be substantiated against the actual published guidance. Ask for the regulation number. They cannot produce one.

The tradability rule inside the Counterparty Screen reads the same published regulatory matrix and returns the sanctions posture we hold for Russian-origin product. It is the leg that flags the SOCAR or KazMunayGas routing claim before the LC opens. Direct access to the endpoint is scoped on a call, with no list price: /apply.

curl -H "Authorization: Bearer $KEY" \
  "https://oilflow.us/api/v1/regulatory/check?product=crude&country=Russia"

{
  "ok": true,
  "data": {
    "country": "Russia",
    "product": "crude",
    "listing_type": "demand",
    "allowed": false,
    "blockers": [
      {
        "country": "Russia",
        "product": "crude",
        "reason": "COMPREHENSIVE WESTERN SANCTIONS BLOCK ALL RUSSIAN-ORIGIN
                   CRUDE FOR EU / UK / US / CH / AU / CA / JP counterparties.
                   EU Council Regulation 833/2014 as amended bans import of
                   Russian-origin crude oil into the EU. G7 Oil Price Cap
                   Coalition prohibits Western maritime services for
                   Russian-origin crude sold above the price cap. OFAC SDN
                   designations cover Rosneft affiliates, Lukoil subsidiaries,
                   Sovcomflot vessels and shadow-fleet operators. UK OFSI
                   maintains parallel regime."
      }
    ]
  }
}