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9/10/2022

Remarks by Deputy Secretary of the Treasury Wally Adeyemo at the Brookings Institution | U.S. Department of the Tr…

U.S. DEPARTMENT OF THE TREASURY
Remarks by Deputy Secretary of the Treasury Wally Adeyemo at
the Brookings Institution
September 9, 2022

As Delivered
Thank you all so much for being here today, and to David and the Brookings Institution for
hosting me. It has been a little more than six months since Russia began its brutal and
unprovoked invasion of Ukraine, the most significant threat in generations to the post-World
War II international order. Over those six months, we have worked with our allies and partners
to mount an unprecedented global response to help end Russiaʼs unjustified aggression. As
part of our overarching strategy to end Russiaʼs invasion we have deployed sanctions with
two primary objectives in mind: to deny Putin revenue to pursue his war of choice and to
erode Russiaʼs ability to wage war going forward by disrupting the critical supply chains
feeding Russiaʼs military-industrial complex.
According to independent academic analysis at Yale, Russiaʼs imports have collapsed by as
much as half, domestic production has been hammered due to shortages of key inputs, and
foreign companies accounting for 40% of Russian GDP have le the country.[1] Moreover, our
sanctions and export controls targeting their military industrial complex have denied Russia
access to critical equipment and imports, degrading their military capabilities in ways weʼre
already seeing on the battlefield—with Russia increasingly reliant on outdated, Soviet-era
weapons without access to the chips needed to replenish their stocks of modern munitions.
However, there is one part of the Russian economy doing even better than when the war
began: their oil industry. This summer, Russia received prices 60 percent higher than last year
for its energy exports, more than o setting the decline in its export volumes.[2] This situation
is unacceptable to us, to our allies, and to the people of Ukraine.
But this situation is also complicated. Consumers and businesses in the U.S. and around the
world are already facing elevated energy prices. Simply banning or sanctioning purchases of
Russian oil might deny Russia some revenue, but it would have the perverse e ect of sharply
increasing global consumersʼ cost of living and increasing the risk of a global recession.
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Remarks by Deputy Secretary of the Treasury Wally Adeyemo at the Brookings Institution | U.S. Department of the Tr…

It is important to remember that the United States and a number of our G7 allies have already
banned the import of Russian oil into our countries. The impact of further actions to prevent
the export of Russian oil to other countries would disproportionately fall on the low- and
middle-income countries still buying it. These countries are already facing high energy and
food prices due to Russiaʼs unprovoked invasion of Ukraine. We know that economic instability
in low-income countries o en leads to political instability, and the last thing we want is for
additional countries to be destabilized by Russiaʼs actions. And, more broadly, we know that
ensuring the continued flow of as much oil as possible onto the global market is critical to
reducing prices in our country and around the world.
That is why, last Friday, the G7 Finance Ministers agreed to finalize and implement an
innovative policy that puts downward pressure on global energy costs by allowing Russian oil
to continue to flow onto the global market while reducing Russian revenue: a price cap on
Russian oil. Today, Iʼd like to share why we think the price cap is so critical, explain how it will
work, and dispel a few myths weʼve heard along the way.
Letʼs start with how it will work. In June, the EU agreed to a sixth package of sanctions that
will ban not only imports of seaborne Russian oil in the EU, but—as of December 5th—will also
ban the provision of associated maritime services like insurance, trade finance, banking,
brokering, and navigation services by companies in the EU to those associated with Russiaʼs
seaborne export of crude oil, regardless of where those shipments are headed. These
maritime services are o en essential—in many cases, seaborne oil shipments cannot be made
without them.
Critically, the providers of some of these services are heavily concentrated in the EU and G7
countries. For example, the EU and G7 provide 90% of global shipping insurance, and they
provide the majority of financing and payments services for the oil trade. One potential
byproduct of this package could be a substantial shut-in of Russian production of oil and
refined product, and associated elevated prices, which could limit or reverse the intentions of
the action. This price increase would undermine the well-intentioned goal of limiting Russiaʼs
revenue from oil sales while imposing an additional and unintentional burden on global
consumers of oil.
The price cap is designed to address this outcome by creating a carveout for services related
to the seaborne transport of Russian oil that is sold at or below the cap level—keeping this oil
on the market and flowing to consumers who need it but still restricting Russian revenue.
Countries outside the G7 can keep buying Russian oil, and companies in the G7 can continue to
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Remarks by Deputy Secretary of the Treasury Wally Adeyemo at the Brookings Institution | U.S. Department of the Tr…

o er services to support those sales—as long as the oil these services support is purchased at
or below a certain price. And in particular, some of the most vulnerable countries in the world
—low- and middle-income oil importers—will benefit most from access to this lower-priced
oil.
When it comes to implementation, two critical pieces are compliance and enforcement—how
market participants know oil is coming from Russia, and therefore needs to be priced below
the cap, and how we deter and punish evasion and knowing violations. On compliance, weʼre
working with the G7 to develop a robust but simple documentation and attestation system
that can give service providers comfort that they are complying appropriately. On
enforcement, those that evade the price cap by falsifying documentation or otherwise hiding
the true origin or price of the oil would face consequences under the domestic law of
jurisdictions implementing the price cap.
Our approach to implementation is guided by the principle that Russian oil should continue to
reach the global market, provided purchasers and service providers abide by the price cap in
good faith.
That is why today, to o er greater clarity to the market and help achieve this objective, I am
announcing that Treasuryʼs O ice of Foreign Assets Control is issuing preliminary guidance on
how this compliance system will work. OFAC will follow up with additional, formal guidance in
the coming weeks to help ensure these compliance expectations are su iciently clear to
facilitate the flow of Russian oil. This action helps formalize the United Statesʼ commitment
to implementing the price cap.
Finally, from a technical perspective, one of the questions Iʼve heard most o en is how the
price will be set. And this relates closely to a common objection Iʼve heard, that Russia will not
sell oil at or below the cap and instead will simply refuse to export. The way the cap is set is
the reason we think that wonʼt happen. Russia may bluster and say they wonʼt sell below the
capped price, but the economics of holding back oil just donʼt make sense: The price cap
creates a clear economic incentive to sell under the cap.
We intend to set the price cap above Russiaʼs marginal cost of production, at a level
consistent with prices they have historically accepted. Russia doesnʼt have much storage
capacity for oil, and many of its wells and equipment are far from state of the art, which
makes it hard for them to stop and later restart production without incurring significant
costs. And that problem is only going to get worse as our sanctions continue to deny them
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Remarks by Deputy Secretary of the Treasury Wally Adeyemo at the Brookings Institution | U.S. Department of the Tr…

access to critical so ware and drilling equipment. As a result, Russia will be forced to continue
selling or risk long-term degradation of its capacity to produce.
That leaves quite a bit of room below both prevailing market prices and the price Russia is
receiving today. It means we have an opportunity to deny Russia the revenue to pursue its
unconscionable war while lowering some of the economic pressure countries around the
world are feeling.
Russia knows that—and itʼs why they are already responding to those clear economic
incentives. They are already o ering long-term contracts to potential buyers at steep
discounts—of 30% or more—far in advance of the price capʼs implementation. The fact that
they are doing this reveals how worried they are and shows how the price cap is already
working to drive down Russiaʼs revenues. We view this as one of the policyʼs key features: that
it can achieve its objectives even if some buyers choose not to formally join because they also
want to pay lower prices for Russian oil. The price cap gives them greater price transparency
and leverage when they negotiate with Russia. So even if Russia tries to get around the cap
with buyers outside our coalition, their revenue will still be driven down, as weʼre already
seeing.
We are clear-eyed that Russia can go find service providers outside the G7 and the other
members of our coalition to replace the maritime services blocked by the EU ban. But these
alternative services will be expensive and less reliable than the services provided by G7 firms.
There is a reason the world relies on EU and G7 firms for the vast majority of these services.
Building up a services ecosystem outside the coalition will cost Russia more money, which will
help reduce the Kremlinʼs revenues even more.

Let me conclude by taking a step back from the details. We are moving forward with this
extraordinary proposal because it is essential that the global community take steps to deny
the Kremlin the revenue it is using to prop up its economy and fight its unjustifiable war in
Ukraine. The price cap seeks to create incentives that reduce Russiaʼs revenues while its oil
continues to flow. The bottom line is that everyone wins but the Kremlin.

This is not an academic conversation. We face the largest ground invasion in Europe since the
end of World War II, one being perpetrated by a regime that will not be easily deterred. It is
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Remarks by Deputy Secretary of the Treasury Wally Adeyemo at the Brookings Institution | U.S. Department of the Tr…

critical that we take this step to deny Russia the revenue they are using to pursue this brutal
invasion while continuing our e orts to disrupt their critical supply chains and degrade their
military-industrial complex. We look forward to your advice on implementation as we move
forward with this policy. Thank you again for being here. Iʼll turn it back to David to introduce a
panel where youʼll hear more on this from my colleague Ben Harris.

[1] https://papers.ssrn.com/sol3/papers.cfm?abstract_id=4167193.
[2] https://www.nytimes.com/2022/06/13/climate/russia-oil-gas-record-revenue.html.

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