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.

OilFlow’s Regulatory Matrix API returns the live sanctions posture for Russian-origin product across 235 jurisdictions. Bank compliance teams call this at counterparty intake so the SOCAR / KazMunayGas routing claim is flagged before the LC opens.

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

{
  "ok": true,
  "data": {
    "allowed": false,
    "status": "blocked",
    "blockers": [
      "OFAC Directive 4 — Russian-origin crude subject to G7 price cap",
      "EU Regulation 833/2014 Annex XXI — embargo on Russian-origin crude",
      "UK SI 2019/855 as amended — UK person prohibition + price cap"
    ],
    "rerouting_warning": "Re-refining via third-country refinery does NOT change origin for sanctions purposes. See EU Commission Notice on price cap implementation."
  }
}