Vladimir Putin signed the decree on Monday, and the state legal portal published it the same day as decree 686, "On approving the list of information in the fuel and energy sector to which access is restricted, and the procedure for its use"; it took effect on signature. It closes the books of Russia's fuel trade to anyone who is not party to a contract. The preamble calls the step an urgent answer to "unfriendly actions, contrary to international law, of the United States of America and the foreign states and international organisations that have joined them", and rests it on the 2018 law on countermeasures against unfriendly acts and the law on information.
The list starts with a company's exports: the names and quantities of the goods, their prices, including the average export price producers set, the sellers and the buyers, and everyone who moves or insures a cargo, carriers, forwarders and insurers among them. It runs on to how contracts are settled, which vessels carry the cargo, the container numbers and transport documents, and the dates and times at which operations with an export cargo begin and end.
It closes the books of Russia's fuel trade to anyone who is not party to a contract.
The geography follows: destinations, routes, the points of transfer, loading and transshipment, the names of sea terminals and their operators, the coordinates of the storage sites where export cargo is accumulated. Next comes the paper: the content of customs documents for exports and a company's aggregated customs statistics. Last come the plants: the volumes a Russian refinery processes and produces.
The last line reaches the exchange: planned sales and concluded deals in petrol of grade 92 and above and in diesel, by a company that dominates its market, by any company in its group or by an exchange trader acting for them, are restricted information. Exchange prices are not named. The volumes behind them are.
Spreading anything on the list, "including through the mass media or information and telecommunication networks", is not permitted. The one exception is information a company discloses about its own activity. Otherwise access runs by agreement between the holder and the recipient, and between state bodies under the law.
The government has 10 days to name the commodity codes under the Eurasian Economic Union's nomenclature and Russia's product classifier. It is also to approve a standard regulation for the automated processing of data drawn from state information systems, with no deadline set, and to bring its own acts into line.
Ten days from Monday is 8 October. That is the last day on which, under section 113 of the Lindsey O. Graham Sanctioning Russia and Iran Act, the US law of 18 September that will put duties on the largest buyers of Russian oil and gas, the United States Trade Representative can hand Congress the written methodology naming the 5 largest importers of Russian crude oil or natural gas over the past 12 months, 10 days before duties of up to 100% fall due on 18 October.
The decree names the United States and not the act. Both clocks meet on 8 October.
The region's fuel imports have been counted from the Russian side. Reuters's count of August, from traders' data, had more than 370,000 tonnes of Russian diesel reaching Kazakhstan, Kyrgyzstan, Tajikistan and Mongolia, about twice July's volume: Mongolia took about 215,000 tonnes, Kyrgyzstan more than 72,000 against 4,400 in July, Tajikistan more than 56,000, Kazakhstan about 28,000. Quantities, buyers, routes and shipment dates are all on the list; whether a trader in Russia may still pass them to a wire is the decree's first test.
The refinery line touches the same customers from the other end. The Moscow refinery has processed nothing since 20 September, after drone strikes damaged its primary units, Reuters reported. Whether a plant runs is not on the list; how much it processes is, and it is that number, summed across Russia's refineries, that tells a buyer in Bishkek or Ulaanbaatar what will be left for export next month.
What stays open is the buyers' side. Kazakhstan's statistics bureau and customs, Kyrgyzstan's cabinet, which on Monday evening published the subsidy it pays importers per litre, Mongolia's emergency fuel headquarters, which counts its stocks in tank wagons: from now on those are the public measures of how much Russian fuel moves east, and at what price. The view from the exporter's side is gone.
The exception for a company's own disclosure leaves Gazprom's issuer reports where they were. Whether the St Petersburg exchange's daily national indices count as its own activity is the first test the text will face; the volumes behind them are on the list by name.
Unresolved: the commodity codes, which decide whether natural gas, pipeline flows and electricity fall under the same lock or only oil products; and what the wires that have printed Russia's monthly export tables from customs data will print in October.