The provision, exportation, or reexportation, directly or
A Notice by the Foreign Assets Control Office on 03/02/2022. any location. In this Issue, Documents should verify the contents of the documents against a final, official This webinar discussed regulatory and enforcement trends in the year ahead, providing insights on the steps that financial institutions can take 2023 is more than a brand-new year it is an opportunity for your company to prioritize supply chain and customs compliance. Attorneys John Pearson and Brandon L. Fyffe of the U.S. Attorneys Office for the Southern District of Texas and Trial Attorneys Lindsay M. Heck and Sinan Kalayoglu of the Criminal Divisions Money Laundering and Asset Recovery Section are leading the seizure action. 03/03/2023, 207 ("BIS").2 Russia and Texas are two of the
Person" means any United States
. such a license will likely be denied as BIS maintains a general
Directive 4 to Executive Order 13662 ("Directive 4"),
include documents scheduled for later issues, at the request without the need to apply for a license. Lukoil OAO is designated under Ofac's Sectoral Sanctions, under EO 13662. treated as being on the SSI List. Given the number of lists that now reside in the Sanctions List Search tool, it is strongly recommended that users pay close attention to the program codes associated with each returned record. guide to the subject matter. Russian oil industry. 3 Briefly, the SDN List identifies individuals and
First, the prohibition potentially now applies to oil
The Specially Designated Nationals and Blocked Persons List and additional information concerning OFAC sanctions programs are available on OFAC's website ( lists maintained by U.S. government agencies. Russia. Aug. 27, 2018) (to be codified in 22 U.S.C. review of any applicable sanctions programs. Parties should also be aware that BIS may inform
In published guidance,14 State has
These sanctions programs included: 1) a trade embargo against Crimea; 2) blocking sanctions against persons listed on the Specially Designated Nationals and Blocked Persons ("SDN") List; and 3) sectoral sanctions prohibiting certain transactions with persons identified on the Sectoral Sanctions Identification ("SSI") List. responds. On February 24, 2022, OFAC determined that the following entities (a) operate or have operated in the financial services sector of the Russian Federation economy, or are foreign financial institutions that are 50 percent or more owned; directly or indirectly, individually or in the aggregate, by one or more such entities; and (b) shall be subject to the prohibtions of Directive 2 under E.O. Bond holders received $34.2 million payment due this week, Sanctioned CEO and co-founder Alekperov stepped down last week. Sanctions Brochures are an overview of OFAC's regulations with regard to the Ukraine-/Russia-related Sanctions. documents in the last year, 83 Litasco will likely retain traders associated with its core energy assets, a senior trading source told Reuters. Some employees, however, chose to leave the company instead, including the former head of chartering David Walker, who joined Nigerian trading firm Sahara. projects" applies to projects that have the potential to
U.S. economic sanctions are a tool of foreign policy that target
Litasco operates four refineries in Russia, further three in Italy, Romania and Bulgaria, and has a 45% interest in the Zeeland refinery in the Netherlands. For example, Company A and Company B
enforced by the Office of Foreign Assets Control
Remarks by Under Secretary for Domestic Finance Nellie Liang During Workshop on Next Steps to the Future of Money and Payments, Remarks by Secretary of the Treasury Janet L. Yellen at Bilateral Meeting with Prime Minister of Ukraine Denys Shmyhal, RT @TreasuryDepSec: At our roundtable with @BlkEconAlliance today, @SBAIsabel @RepNikema and I heard from business leaders about ways the f, RT @TreasuryDepSec: I'm in Atlanta this week with @SBAIsabel and @DepSecTodman to highlight some of the historic investments @USTreasury @S, Form 941, employer's quarterly federal tax return, Consolidated Sanctions List (Non-SDN Lists), Civil Penalties and Enforcement Information, Complete Sectoral Sanctions Identifications List (PDF format), Complete Sectoral Sanctions Identifications List (TEXT format). Under the most extreme scenario, companies operating in the UK, US or EU including most of the worlds major financial institutions could be forbidden from any transactions with sanctioned entities. Security, Regulations, Export Administration Regulations, Pt. purposes of Directive 4, services does not include the provision of
4024, https://www.federalregister.gov/d/2022-04337, MODS: Government Publishing Office metadata. A specific license from DOC is required for the export, reexport or transfer (including in-country transfer) of any item subject to the EAR to any of these companies if it is known that the items will . documents in the last year, 987 Section 746.5 of the Export
website: While the above focuses on primary sanctions, CAATSA also
Lawyers for Abramovich, speaking last week before Russia declared that it recognised the independence of the two self-proclaimed republics in eastern Ukraine, disputed that he or Evraz fitted the criteria for potential designation for sanctions. There is thought to be more Russian gold in London than in any other city in the world. and Eurasia Act of 2017 ("CRIEEA"), codified many of the
OFAC issues advisories to the public on important issues related to the sanctions programs it administers. POPULAR ARTICLES ON: International Law from United States. a country other than Russia could be subject to the prohibitions of
the Department of the Treasury. transaction are screened. 03/03/2023, 827 Only official editions of the Our Standards: The Thomson Reuters Trust Principles. Gazprom is the supplier of gas that is supposed to flow through the controversial Nord Stream 2 pipeline, which will be operated by a Swiss entity, Nord Stream 2 AG. The company is 29% owned by Roman Abramovich, the Russian owner of Chelsea football club. So, conduct that does not
assume it is not clear from the sales agreement who the owner of
New Documents This table of contents is a navigational tool, processed from the 14024, Prohibitions Related to New Debt and Equity of Certain Russia-related Entities. These names have been placed on OFAC's Non-SDN Menu Based Sanctions List (NS-MBS List). The spokesperson highlighted a list of big institutional shareholders ranging from Goldman Sachs and BlackRock in the US to British asset managers such as Schroders and abrdn, and said it made a notable contribution to the sustainability of the UK energy market. comfortable. documents in the last year, 123 passed in response to Russia's cyber meddling in the 2016
14024, Prohibitions Related to Correspondent Accounts and Processing of Transactions Involving Certain Foriegn Financial Institutions. These names have been placed on OFAC's List of Foreign Financial Institutions Subject to Correspondent Account or Payable-Through Account Sanctions. the SSI List and specifically identified as subject to Directive 4. Sanctioned companies can, depending on the details, be suspended from trading and removed from the LSEs stock market indices although there is little in the rules on what would happen if suspensions were to last years. In August 2017, President Trump signed the Countering
However, Deripaska has taken legal action to challenge US sanctions. In 2014, the Obama
We need this to enable us to match you with other users from the same organisation. permissible. Federal Register provide legal notice to the public and judicial notice individuals with whom U.S. (and sometimes non-U.S.) persons are
Washington, D.C. 20220 U.S. parties seeking to do business with the Russian oil industry. OFAC issues general licenses in order to authorize activities that would otherwise be prohibited with regard to Ukraine-/Russia-related Sanctions. Litasco says it does not comment on the employment status of its workforce. prohibited. daily Federal Register on FederalRegister.gov will remain an unofficial Since September 2014, LUKOIL has been subject to sectoral sanctions imposed by the U.S. Department of the Treasurys Office of Foreign Assets Control. 1 Exec. the SSI List and owns an unknown percentage of Company B. Vladimir Putins friend Gennady Timchenko is among those to have been hit by UK sanctions over Ukraine. 18 These parts cannot be exported,
not be used in a shale project? Register notice was published on August 27, 2018 and more
in which any person determined to be subject to this Directive
certain types of transactions with SSI-Listed entities are
formations. visited Aug. 31, 2018). OFAC does not provide recommendations with regard to the appropriateness of any specific confidence rating. OFACissues interpretive guidance on specific issues related to the sanctions programs it administers. 200. stations. The Boeing is believed to be in Russia and worth approximately $45 million. Some of these authorities are in the form of an executive order issued by the President. This years Innovation Summit featured finalists selected by the Earthshot council in addition to panelist speakers from heads of state, grassroots organizations and tech leaders. Litasco, which was handling more than 3.6 million barrels per day, is now focusing on sending crude to Lukoil's European refineries and selling refined products, traders said. Director, Office of Foreign Assets Control, U.S. Department of the Treasury. Of all the countries that could retaliate economically, the UK has an outsized ability to inflict damage. Sign Up for our free News Alerts - All the latest articles on your chosen topics condensed into a free bi-weekly email. : 202-622-2490. prominent Russian energy companies, such as Gazprom, Lukoil, and
Therefore, a project with a Russian company as a minority owner in
require a specific license would be conduct authorized by a general
What changed on the list when it was last updated (PDF format)? The Boeing last flew into the United States in March 2019 when the plane flew from overseas to Houston, Texas with LUKOIL officials, including a Russian oligarch then LUKOIL president and CEO Vagit Alekperov on board the aircraft. Remarks by Assistant Secretary Elizabeth Rosenberg for Terrorist Financing and Financial Crimes at the Association of Women in International Trade. Reuters, the news and media division of Thomson Reuters, is the worlds largest multimedia news provider, reaching billions of people worldwide every day. Support Act of 2014, Pub. L. No. On February 24, 2022, OFAC determined that the property and interests in property subject to U.S. jurisdiction of the following persons are blocked under the relevant sanctions authority listed below. U.S. persons are generally prohibited from engaging in transactions with them. Remarks by Assistant Secretary Elizabeth Rosenberg for Terrorist Financing and Financial Crimes at the Association of Women in International Trade. &. documents in the last year, by the Nuclear Regulatory Commission This feature is not available for this document. be helpful in deciding whether or not a transaction is
that (1) involve operations originating offshore, and (2) are
This special Bloomberg program highlights the event's biggest interviews and news makers. Build the strongest argument relying on authoritative content, attorney-editor expertise, and industry defining technology. Insight and analysis of top stories from our award winning magazine "Bloomberg Businessweek". Assistant U.S. The United States and Britain have targeted Russian energy exports with sanctions after Russia's invasion of Ukraine late last month, and many EU companies have imposed hefty measures against Russia, including freezing its central bank's assets. Some oil traders are actively avoiding transactions with Litasco SA, the trading unit of Russian oil producer Lukoil, fearing their products will get stranded if . The 50% rule states that an entity that is owned 50% or
SSI List. 2 to Part
The OFR/GPO partnership is committed to presenting accurate and reliable It may be in your and the U.S. governments interest to authorize particular economic activity related to the Ukraine-/Russia-related Sanctions. ("OFAC"), a government agency within the U.S. Department
the current document as it appeared on Public Inspection on Another important aspect of Directive 4 is the meaning of the
[]; or. financial services, clearing transactions or providing insurance
technology in support of exploration or production for deepwater,
Part of Directive 4
Sanctions List Search has a slider-bar that may be used to set a threshold (i . instrumentalities (including any entity owned or controlled
The U.S. Attorneys Office for the Southern District of New York, the FBIs New York Field Office and the Federal Aviation Administration provided significant assistance. Gazprom is among the Russian companies to have raised money in London. prohibition focuses on ownership of or voting interests in the
The list of parties subject to Directive 4 includes several
to authorize that person or entity to engage in a particular
Because the minutia of the above can be complex, the following
2 to part 746 of the EAR as well as specific parts identified
for better understanding how a document is structured but +67.00 +1.74%. documents in the last year, 20 on That mood has changed along with the geopolitics since the Crimea annexation, but Russian companies have still raised an average of $1.8bn a year on the LSE between the 2014 Crimea invasion and 2021, or 14bn in total, according to data from Dealogic. on exports to the Russian oil industry. 17 The CSL is found at https://www.export.gov/csl-search.18. a series of Executive Orders. Use the PDF linked in the document sidebar for the official electronic format. : 202-622-2490; Associate Director for Global Targeting, tel. 746Russian Industry Sector Sanction List (2017), https://www.bis.doc.gov/index.php/documents/regulation-docs/420-part-746-embargoes-and-other-special-controls/
Vagit Alekperov, the head of Russia's No.2 oil producer Lukoil, said on Thursday the banks had become more demanding when dealing with his company after Washington published a so-called "oligarch . (last visited Aug. 31, 2018). 115-44, 131 Stat. against the SSI and SDN Lists, as well as any other denied party
Because the Directive 4 prohibitions hinge on the involvement of
that focuses on Russia, the Countering Russian Influence in Europe
In the latest string of Russian sanctions related developments,
region of Ukraine. Certain activities related to the Ukraine-/Russia-related Sanctionsmay be allowed if they are licensed by OFAC. OFAC publishes a list to identify persons operating in sectors of the Russian economy identified by the Secretary of the Treasury pursuant to Executive Order 13662. Reg. 3,907.00. All parties to the transaction should be screened
publication in the future. Construction Project Cost Reporting Risks And How To Manage Them After Security Exchange Commission v. Granite Construction, Inc. Mondaq Ltd 1994 - 2023. of reasons. types of licenses: general licenses and specific licenses. track of sanctions depending on how the Russian government
documents in the last year, 667 section for applicable date(s). This comprehensive, bipartisan sanctions
: 202-622-4855; or the Assistant Director for Sanctions Compliance & Evaluation, tel. Budget, Financial Reporting, Planning and Performance, Financial Markets, Financial Institutions, and Fiscal Service, Treasury Coupon-Issue and Corporate Bond Yield Curve, Treasury International Capital (TIC) System, Kline-Miller Multiemployer Pension Reform Act of 2014, Taxpayers Will See Improved Service This Filing Season Thanks to Inflation Reduction Act, Disparities in the Benefits of Tax Expenditures by Race and Ethnicity, Racial Differences in Economic Security: Non-Housing Assets, Treasury Sanctions People Involved in Serious Human Rights Abuse Against Vladimir Kara-Murza, Treasury Announces Approval of Up to $890.7 Million to Support Small Business Success Across Three States, Treasury Sanctions CJNG-Run Timeshare Fraud Network. Share Your Design Ideas, New JerseysMurphy Defends $10 Billion Rainy Day Fund as States Economy Slows, What Led to Europe's Deadliest Train Crash in a Decade, This Week in Crypto: Ukraine War, Marathon Digital, FTX. is required for a specific end-use or end-user because there is a
certain transactions with persons identified on the Sectoral
include, for example, drilling services, geophysical services,
The Sectoral Sanctions Identifications List includes persons determined by OFAC to be operating in sectors of the Russian economy identified by the Secretary of the Treasury pursuant to Executive Order 13662. ownership structure of some Russian companies and oil projects, so
Learn more about LUKOIL's business. To print this article, all you need is to be registered or login on Mondaq.com. ("State") is tasked with administering Section 225 and
more by an individual or entity on the SSI List will also be
The new sanctions will significantly extend the Ukrainian sanctions program against Russia by placing more than 400 companies and 1000 individuals including: Public Guidance, CAATSA/CRIEEA Section 225 Public Guidance
13 April 2022. (2017), https://www.state.gov/e/ enr/275194.htm (last
authorizes a particular type of transaction for a class of persons
Notably, OFAC's 50% rule applies for purposes of the
Executive Orders implemented during the Obama
involve any person determined to be subject to this Directive
Oct 10 (Reuters) - The trading arm of Russia's Lukoil, Litasco, has moved part of its operations to Dubai over the last few months as European sanctions on Moscow push traders to neutral territory, according to trade sources familiar with the matter. This repetition of headings to form internal navigation links Sectoral Sanctions Identifications (SSI) List, Budget, Financial Reporting, Planning and Performance, Financial Markets, Financial Institutions, and Fiscal Service, Treasury Coupon-Issue and Corporate Bond Yield Curve, Treasury International Capital (TIC) System, Kline-Miller Multiemployer Pension Reform Act of 2014, Taxpayers Will See Improved Service This Filing Season Thanks to Inflation Reduction Act, Disparities in the Benefits of Tax Expenditures by Race and Ethnicity, Racial Differences in Economic Security: Non-Housing Assets, Treasury Sanctions People Involved in Serious Human Rights Abuse Against Vladimir Kara-Murza, Treasury Announces Approval of Up to $890.7 Million to Support Small Business Success Across Three States, Treasury Sanctions CJNG-Run Timeshare Fraud Network. documents in the last year, by the Energy Department While U.S. For complete information about, and access to, our official publications (last visited Aug. 31, 2018). transaction. Venezuela, among others, are subject to OFAC-administered
investigated to determine the potential involvement of sanctioned
informational resource until the Administrative Committee of the Federal involvement of a Directive 4-subject person. The President of the United States manages the operations of the Executive branch of Government through Executive orders. Previously worked at Euromoney Institutional Investor and CNN. sanctions/Programs/Documents/eo13662_directive4_20171031.pdf (last
OFAC also applies the 50% Rule in
Register documents. transactions between U.S. persons and individuals or entities
better and aid in comparing the online edition to the print edition. other foreign policy-based concerns, such as terrorism, narcotics
transaction and determine the level of risk with which they are
Directive 4. According to OFAC, a project is initiated when, "a government
throughout. . value of the transaction that was the basis for the violation. "They are slowly moving to Dubai. sanctions. ("SDN") List; and 3) sectoral sanctions prohibiting
Foreign Secretary announces 178 new sanctions, coordinated with the EU, targeting those who prop up Russian-backed illegal breakaway regions of Ukraine. All Rights Reserved. While every effort has been made to ensure that 8 See FAQ 536, U.S. Dep't of the Treasury,
Register (ACFR) issues a regulation granting it official legal status. Even when OFAC and other relevant agencies provide guidance, few
Importantly, this
institutions that knowingly engage in or facilitate significant
example aims to highlight the issues encountered during a Directive
Additionally, it is notoriously difficult to determine the
Commerce's export control agency, BIS, has its own prohibitions
project by a Directive 4-subject person, rather than just the
16,169 (Mar. high risk of use in the activities specified above. SDN List last updated on: 3/3/2023 10:07:05 AM, Non-SDN List last updated on: 2/24/2023 9:02:31 AM, Executive Order 13662 Directive Determination -, Ukraine-/Russia-Related Sanctions Regulations, 31 CFR 589.201 and/or 589.209. the U.S. government finds that Russia does not meet certain
Specifically, we will provide an overview of
No. are not part of the published document itself. are not limited to, OFAC's SSI and SDN Lists, and the BIS
produce oil from resources located in shale
March 24 (Reuters) - The Swiss trading arm of Russian energy giant Lukoil (LKOH.MM) has scaled back operations after the oil company cut its supply of capital to guarantee nearly $1 billion in margin calls in the wake of Western sanctions, according to three people familiar with the matter. Russia, and hydraulic fracturing is most often associated with
The London-based aluminium miner En+ Group (1.1bn), which raised $1.5bn on the LSE in a 2017 float, has already had to navigate the challenge of sanctions on a related party. documents in the last year, 517 these parties and the interests held in oil projects must also be
bright line rules exist. address of an individual or company on the CSL, parties are able to
underwater activities at depths of 500 feet or
All Rights Reserved, have the potential to produce oil in
A statutory instrument laid before parliament earlier this month gave the UK government the power to impose sanctions on those carrying on business of economic significance to the government of Russia as well as companies supportive of the Russian government, and sectors of strategic significance, including energy, mining and financial services. Entering into a transaction with a party on a denied
on Sanctions Identification ("SSI") List.3
The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) is publishing the names of one or more persons or property that have been placed on one or more of OFAC's sanctions lists based on OFAC's determination that one or more applicable legal criteria were satisfied. electronic version on GPOs govinfo.gov. Ukraine-/Russia-related Directives, Office of Foreign Assets
From Rosneft to Gazprom and En+ Group, most significant London-listed firms potentially face sanctions. This consolidated list includes the Foreign Sanctions Evaders List, the Sectoral Sanctions Identifications List, the List of Foreign Financial Institutions Subject to Correspondent Account or Payable-Through Account Sanctions, the Non-SDN Palestinian Legislative Council List, the Non-SDN Menu-Based Sanctions List, and the Non-SDN Communist assurances from Company B stating that the project is not a shale
14 U.S. Dep't of State, Energy Sanctions, Section 225
The Earthshot Prize 2022 is a global prize designed to incentivize change and help to repair our planet by awarding five winners each year for their contributions to environmentalism. Build the strongest argument relying on authoritative content, attorney-editor expertise, and industry defining technology. 03/03/2023, 234 provide legal notice to the public or judicial notice to the courts. This PDF is action. They will have nothing to do in Switzerland," one of the trading sources said. discuss Russian oil sector prohibitions administered by the
No companies or individuals have yet been designated, but the new legislation now allows for the speedy designation of a very broad range of individuals and entities. The use of Sanctions List Search does not limit any criminal or civil liability for any act undertaken as a result of, or in reliance on, such use. rendition of the daily Federal Register on FederalRegister.gov does not of Ukraine. : 202-622-2420; Assistant Director for Licensing, tel. Oct 10 (Reuters) - The trading arm of Russia's Lukoil, Litasco, has moved part of its operations to Dubai over the last few months as European sanctions on Moscow . President is required to impose sanctions on non-U.S. persons that
Some companies with primary London listings also operate in sectors deemed by the UK government as strategically significant to Russia. Exclusive: Russia set to mothball damaged Nord Stream gas pipelines - sources, Oil settles up on China demand hopes, posts weekly gain, Reporting by Laura Sanicola in Washington and Julia Payne in London Lukoil OAO, Rosneft and Surgutneftegas. OFAC publishes a list to identify persons operating in sectors of the Russian economy identified by the Secretary of the Treasury pursuant to Executive Order 13662. 03/01/2022 at 8:45 am. Sanctions List Search has a slider-bar that may be used to set a threshold (i.e., a confidence rating) for the closeness of any potential match returned as a result of a user's search. Sanctions have made an impact on the activities of all energy companies in Russia, including Lukoil, as any restrictions do, said Alekperov, adding that investment ratings are lower, and access to capital markets and technology is being restricted. secondary sanctions on Russian or other foreign financial
Persons generally are
Screen for heightened risk individual and entities globally to help uncover hidden risks in business relationships and human networks. Register, and does not replace the official print version or the official Industry Sector Sanctions; Supplement No. The content of this article is intended to provide a general
and services, go to andthe assets of SDNs in the United States are blocked (frozen) by
by the Foreign Assets Control Office ). The Ukraine-/Russia-related Sanctionsprogram represents the implementation of multiple legal authorities. From Dec. 5, European and Swiss entities will not be able to buy Russian seaborne crude oil and from February, refined products will also be banned. Countering America's Adversaries Through Sanctions
Trading firms have become wary of dealing with Litasco owing to credit concerns. Since the 1990s, companies whose shares are traded in Moscow have turned to London to raise money through what are known as secondary listings. case. Reports on oil and energy, including refineries, markets and renewable fuels. They range from state-backed oil and gas producers Rosneft and Gazprom, to state-run banks VTB and Sberbank, to independent mining companies such as Nornickel that have no state ownership. Company B is a subsidiary of Company C, which is on
("CAATSA"). Additionally, if the party is unable to determine whether the
The U.S. District Court for the Southern District of Texas authorized the seizure, finding probable cause that the Boeing aircraft was subject to seizure based on violations of federal law. are both listed on the SSI List. Specialist advice should be sought
and Interests in Property are Blocked (2014), https://www.treasury.gov/resource-center/sanctions/Pages/default.aspx
that there are no prohibitions on the transaction and conduct a
Screen for heightened risk individual and entities globally to help uncover hidden risks in business relationships and human networks. modeling capabilities, and mapping technologies. restricted or prohibited from transacting. Each document posted on the site includes a link to the LUKOIL has communicated its commitment to assist its finance partners to understand the scope of these sanctions measures with respect to the Company so that These names have been placed on OFAC's List of Specially Designated Nationals and Blocked Persons.
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