New individuals and entities added to sanctions list. On October 31, 2017, the Office of Foreign Assets Control (OFAC) took a number of actions to implement the Countering Russian Influence in Europe and Eurasia Act (CRIEEA) (also known as the Countering America’s Adversaries Through Sanctions Act (CAATSA), a larger sanctions statute of which CRIEEA was a part). The sanctions lists have increased each year and now consist of more than 500 companies and 300 individuals. The US Department of Treasury’s Office of Foreign Assets Control (OFAC) has issued additional sanctions targeting certain Russian banks, energy and defense companies. The amendment implemented Section 223 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), signed into law by President Trump last … Inevitably, decisions by the US Treasury have a larger impact on the companies doing business with targeted nations. 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. OFAC has imposed certain restrictions on transactions with the financial, energy, and defense sectors in Russia • OFAC published the Sectoral Sanctions Identification List (“SSIL”), which identifies entities subject to these restrictions − OFAC issued 4 Directives, which set forth groups of entities subject to different restrictions LITASCO Operations executes all crude and product trading agreements through a global network of commercially focused operators. which could also have enhanced consequences for Russian companies and financial institutions – COVID-19 / Russia sanctions link: April 2020 report that the USG has purchased a large shipment of ventilators, face masks etc. OFAC Announcement of Expanded Treasury Sanctions within the Russian Financial Services, Energy and Defense or Related Materiel Sectors 9/12/2014 ... Gazprom, Gazprom Neft, Lukoil, Surgutneftegas, and Rosneft – involved in these types of projects. The US Department of Treasury’s Office of Foreign Assets Control (OFAC) has issued additional sanctions targeting certain Russian banks, energy and defense companies. ... Lukoil… + & 1/:099*:0/ &$,.32,3- H,--, "25,. and all the SDN designations / sanctions also administered by OFAC(based on various Eos) and Treasury’s further expansive secondary sanctions authorities under CAATSA (slides37-50) – Commerce Dep't ( Bureau of Industry and Security –BIS) export restrictions – 15 CFR §746.5, § 746.6 Crimea region of Ukraine. The government has expanded sanctions and export controls against Russia's energy, defence and financial services sectors. First, OFAC has revised Directive 1, issued pursuant to Executive Order 13662, 1 which remains applicable … The sanctions, issued September 12, 2014, are intended to increase the cost to Russia as it continues to violate Ukraine’s territorial integrity and sovereignty. Under a new rule, the U.S. Bureau of Industry and Security (BIS) has added a Russian oil and gas field, the Yuzhno-Kirinskoye Field located in the Sea of […] 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. Zulutrade failed to screen or otherwise monitor its customer base for OFACÂ compliance purposes at the time of the apparent violations. OFAC amended Directive 1 and … Last Updated: 03/12/2020 Sign up for SSI List e-mail updates. This morning OFAC added a … The BIS action is in addition to the U.S. Department of… Short summaries of the sanctions are provided below, with differences between EU and US sanctions noted. OFAC has also tightened capital market restrictions for entities on its Sectoral Sanctions Identifications List (SSIL) and added firms in the Russian defense sector. The Russia (Sanctions) (EU Exit) Regulations 2019 came fully into force on 31 December 2020. Other authorities are public laws (statutes) passed by The Congress. OFAC issues new guidance on the Russia sanctions through new FAQs. OFFICE OF FOREIGN ASSETS CONTROL Sectoral Sanctions Identifications List March 12, 2020 - 3 - 911/98!*191! § 746.7 Iran. Analytical cookies help us improve our website by providing insight on how visitors interact with our site, and necessary cookies which … C A M E R A O B S C U R A Russian corporate structures are intricate, perhaps intentionally so. In 2018, the Russian government responded to harsh sanctions by passing a law that enabled it to limit access to legal entity registers, preventing firms in the US and the EU from gaining visibility into company ownership. This alert provides key takeaways and compliance pointers. The United States Treasury Department of Foreign Assets Control Office (OFAC) said in a statement that Bank Mellat and Mehr Eqtesad Bank, one of the leading banks in Iran, were added to the sanctions list. New Russian sanctions add parties to SSIL and SDN lists. The US Treasury Department, Office of Foreign Assets Control (OFAC) ... Lukoil, Rosneft, and Surgutneftegas. Posted by Clif Burns at 1:48 pm on September 12, 2014. United States is the world’s largest economy representing 17% of the World’s GDP. Gazprom PJSC reached an agreement to continue onshore gas supplies to Europe via Ukraine as the U.S. administration imposed sanctions on … This rule provides guidance on how exporters should treat the twenty entities currently on the Entity List with references to § 746.5 (Russian Industry Sector Sanctions). Supplement No. OFAC issued a corresponding Sectoral Sanctions Identification List (SSI), prohibiting US persons from doing business with specified individuals or entities in identified business sectors. The list of parties subject to Directive 4 includes several prominent Russian energy companies, such as Gazprom, Lukoil, and Rosneft. The US rules present similar challenges as a result of OFAC’s recent clarification that entities owned 50% or more by persons designated under US sanctions will also be subject to sanctions, even if no single designated person owns a majority interest. Earlier today, September 12, 2014, the EU and US published yet more sanctions on Russia, increasing the pain particularly in the investment services, defense and oil exploration worlds. from KRET, a Russian SDN subsidiary of Rostec Gazprom reached an unspecified accord with Iran’s state natural gas company, and its subsidiary Gazprom Neft PJSC signed a deal to study the Cheshmeh-Khosh and Changuleh oil fields. “There’s nothing revolutionary in the fourth directive on technological sanctions in the oil sector…. OFAC does not address the revised 50% rule in its latest FAQs, but U.S. companies must keep in mind that the Russia sanctions also extend to entities that are not listed, but that are 50% or more owned by SDN or SSI-listed entities. This article provide limited overview on compliance with OFAC sanctions. On October 31, 2017, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) amended and reissued Directive 4 of the Ukraine/Russia-related sectoral sanctions (“Directive 4”), which targets the Russian energy sector, and updated its guidance regarding the implementation of Ukraine/Russia-related sanctions. The Russia sanctions regime. Economic Sanctions Targeting Exchanges with Russia in Specific Economic Sectors OFAC Sanctions. New Russian Sanctions Add Parties to SSIL and SDN Lists. 13662, which was issued on March 20, 2014. On 1 October, the Council added new individuals and entities to the list of those individuals and entities subject to restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine. First, OFAC has revised Directive 1, issued pursuant to Executive Order 13662, 1 which remains applicable to SSIL designees in the Russian financial sector. The Office of Foreign Assets Control (OFAC), a unit of … Yesterday, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced increased economic sanctions against Russia, … OFAC Trade Restrictions. New US Sanctions. EU Sanctions Authorities Start to Show Their Teeth. State-run Gazprom is the third Russian energy company to sign a memorandum of understanding with Iran, joining Lukoil PJSC and Zarubezhneft OAO. The Latvian government now passed on legislation ending Lembergs' control of the port. At the moment, the SDN, as it’s known, is 937 pages. They are intended to ensure that certain sanctions … Sanctions are a central element of U.S. policy to counter and deter malign Russian behavior. As part of this, OFAC amended Directive 4 under Executive Order … It's ranked as the 40th largest corporation in the world, up from 43 the previous year. Complementing the OFAC sanctions, the Commerce Department’s BIS announced that it would add the defense entities ... Lukoil, Rosneft, and Surgutneftegas to its Entity List. OFAC introduces the Sectoral Sanctions Identifications (SSI) List for the purposes of applying tailored, “sectoral” sanctions to a number of entities in accordance with E.O. Notably, OFAC’s 50% rule applies for purposes of the SSI List. The letter is accompanied by a list of companies subject to sanctions, including enterprises of Gazprom, Rosneft, LUKoil and Surgutneftegaz. For example, Russia’s Lukoil maintains 311 different corporate entities … Involving persons that OFAC designates under Directive 4 on the Sectoral Sanctions Identifications List (SSI List) This prohibition is broad, and applies to all goods, services, and technology, whether US origin or foreign origin. This morning OFAC added a number of Russian entities to the SSIL and SDN Lists. OFAC Sanctions. OFAC has also tightened capital market restrictions for entities on its Sectoral Sanctions Identifications List (SSIL) and added firms in the Russian defense sector. This client advisory highlights the substantive changes of OFAC’s new directives. In the United States, on September 12, 2014, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) broadened sectoral sanctions issued pursuant The U.S. Government and the European Union (“EU”) have expanded sanctions and export controls against Russia’s energy, defense and financial services sectors. For these entities, BIS will impose a license requirement for the export, re-export, or foreign transfer of items subject In the United States, on September 12, 2014, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) broadened sectoral sanctions issued pursuant Operating teams are organized with a reporting line to the CEO independent of Trading. They are based in our main trading hubs, Geneva, Rotterdam, Singapore, New York, Houston, Hamburg and Dubai.Operators are pivotal to the LITASCO execution … The new sanctions will significantly extend the Ukrainian sanctions program against Russia by placing more than 400 companies and 1000 individuals including: Russian oil and gas companies Rosneft, Lukoil and Transoil; New US Sanctions. 10/*9 1: ;&. OFAC Trade Restrictions. … OFAC’s explanation is simply that Zulutrade had no idea it needed to comply with U.S. sanctions, perhaps not surprising in the case of a company sitting in Greece even if incorporated in Delaware. OFAC has also tightened capital market restrictions for entities on its Sectoral Sanctions Identifications List (SSIL) and added firms in the Russian defense sector. These include major entities such as Gazprom, Rosneft, Lukoil, Surgutneftegas, and several refineries. Litasco, the international trading arm of Russia’s second-biggest oil producer Lukoil, stopped its oil swaps deals with Venezuela immediately after the U.S. imposed sanctions … On August 2, 2017, President Donald Trump signed into law H.R. On October 31, 2017, the Office of Foreign Assets Control (OFAC) took a number of actions to implement the Countering Russian Influence in Europe and Eurasia Act (CRIEEA) (also known as the Countering America’s Adversaries Through Sanctions Act (CAATSA), a larger sanctions statute of which CRIEEA was a part). Rosneft, the Russian oil and gas company run … Lukoil—alongside Gazprom, Gazprom Neft, Surgutneftegas, and Rosneft—has been since 2014 on the U.S. Treasury sanctions list that prohibits the exports of goods, services (not including financial... Sanctions apply to all the projects with at least 33-percent participation of the sanctioned companies. LUKOIL has been looking at opportunities of expanding our business in Iraq since late 1990’s, when an agreement had been reached with the then government of Iraq to develop the West Qurna field. § 746.8 [Reserved] § 746.9 Syria. It lists thousands of names or entities. Today is the effective date of the expanded sanctions set out in Directive 4 under the US Russia sanctions program, as amended by the US Department of Treasury, Office of Foreign Assets Control (OFAC) on October 31, 2017. On March 16, 2014, the President issued E.O. Reg. – The North Korea sanctions provisions (Section 7101 et seq.) Russia, USA September 12 2014. OFAC does not address the revised 50% rule in its latest FAQs, but U.S. companies must keep in mind that the Russia sanctions also extend to entities that are not listed, but that are 50% or more owned by SDN or SSI-listed entities. Subscribe to the OFAC RSS feed (includes notices of SSI List updates). The sanctions, issued September 12, 2014, are intended to increase the cost to Russia as it continues to violate Ukraine’s territorial integrity and sovereignty. The targeting of Lukoil is notable as the first private Russian company to be subject to US sectoral sanctions. § 746.5 Russian industry sector sanctions. In conjunction with the rollout of new Ukraine-related sanctions on September 12, 2014, OFAC provided additional information regarding the scope and application of the Sectoral Sanctions in the form of additions to its list of Frequently Asked Questions (FAQs). Two and a half years into Donald Trump’s presidency, there is no doubt that economic sanctions are his administration’s foreign-policy weapon of choice. The renewed document includes all the provisions approved in September 2014, as well as the novations outlined by the new legislation on American sanctions, signed by Trump in … The U.S. Government and the European Union (“EU”) have expanded sanctions and export controls against Russia’s energy, defense and financial services sectors. Our experience in researching sanctions ownership in relation to the Ukraine- related sanctions involved many twists, turns and dead ends. OFAC ended the week on a high note, adding the following entities to the Sectoral Sanctions Identification (SSI) List: The US Department of the Treasury has imposed new financial sanctions on Iran’s oil industry. The Ukraine-/Russia-related Sanctions program represents the implementation of multiple legal authorities. Executive Order 13662. and first implemented by OFAC Directives 1 and 2 in July 2014. On 31 March 2020, the UK's Office of Financial Sanctions Implementation (OFSI) announced that the Economic Secretary to the Treasury had upheld the decision to impose two fines on Standard Chartered Bank for breaching EU financial sanctions on Sberbank and its former subsidiary Denizbank A.S. Under US and EU rules, therefore, it may be difficult for banks and . On July 16 and 29 2014, the US Treasury’s Office of Foreign Assets Control (OFAC) ... Lukoil OAO, Rosneft and Surgutneftegas. Category: Russia Designations. October 5, 2019, 7:00 AM. On 18 December 2019 OFAC removed sanctions imposed on the Ventspils Freeport Authority, designated on 9 December 2019 for being owned/controlled by Aivars Lembergs. The US Treasury Department, Office of Foreign Assets Control (OFAC) has issued Directive 4 prohibiting US persons from supplying, exporting or reexporting any goods, services, and technology: Related to exploration and production for oil in Russian deepwater, Arctic offshore, and shale projects There, says Neylan, you can go online and find a single searchable document — the Office of Foreign Assets Control’s (OFAC) Specially Designated Nationals and Blocked Persons list. A key feature of the U.S. sanctions against Russian business interests has been the creation of the Sectoral Sanctions Identifications List (SSI List). READ MORE: Anti-Russia Sanctions Have No Impact on Rosneft's Oil, Gas Shelf Projects 13661 pursuant to, inter alia, IEEPA, to expand the national emergency declared in E.O. The U.S. has tightened its grip on Russia through an expansion of its previously announced sanctions covering Russia’s oil industry, due to the latter’s involvement in the Ukraine crisis. In the latest installation of FAQs OFAC confirmed the following: 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 … Â Those new designations are the following: The Treasury Department's Office of Foreign Assets Control has broadened sectoral sanctions targeting Russia's defence sector and additional entities and activities in the energy sector. Lukoil’s corporate “map” has over 300 separate legal entities, for example. Russia’s largest banks, oil producers and defence companies will be cut off from international finance and technology under sweeping new economic sanctions announced by … Also on 12 September OFAC issued General License No. Some of these authorities are in the form of an executive order issued by the President. LITASCO Operations executes all crude and product trading agreements through a global network of commercially focused operators. The impact of OFAC’s amended and new directives is to create a more complex sanctions regime, requiring additional due diligence for firms dealing with SSI listed entities. Russia Sanctions List. These sanctions are immediately applicable to five Russian energy companies – Gazprom, Gazprom Neft, Lukoil, Surgutneftegas, and Rosneft – involved in these types of projects. September 12, 2014: OFAC Ukraine-related sanctions list changes, licenses By eric9to5 on September 15, 2014 • ( Leave a comment). In 2014 the US, EU and other states imposed a range of sanctions on Russian companies and individuals in connection with the annexation of the Crimea and Russia's involvement in a military conflict in Eastern Ukraine. It’s a different story in the United States. Russia Sanctions: Amended OFAC Directive 4 Effective Today. Subsection 1 prohibits U.S. persons from providing goods, services (except financial services), or technology in support of projects in Russia for exploration or production of oil from deepwater, Arctic offshore, or shale that “ involve ” designated Russian entities or their subsidiaries. next. Gazprom is Russia's largest. 13660 in order to address the actions and polices of the Government of the Russian Federation with respect to Ukraine, including the deployment of Russian Federation military forces in the Crimea region of Ukraine. 2 to Part 746 - Russian Industry Sector Sanction List Last Friday, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) dramatically increased targeted economic sanctions and export controls against several Russian energy and defense companies, including Gazprom OAO, the largest gas extraction company in the world, and privately-owned petroleum company, Lukoil. The US Treasury Department’s Office of Foreign Assets Control (OFAC) OFAC expanded the so-called “sectoral sanctions” previously issued under . 1 OFAC Directive 1 (as amended) under Executive Order 13662. up 2 OFAC Directives 2 and 4 under Executive Order 13662. up 3 OFAC Directive 4 under Executive Order 13662. up 4 OFAC Directive 2 (as amended) under Executive Order 13662. up 5 Russian Sanctions: Addition of Persons to the Entity List and Restrictions on Certain Military End Uses and Military End Users, 79 Fed. 1 to Part 746 - Examples of Luxury Goods; Supplement No. Takeaways from OFAC's latest guidance on Russia sanctions. For all UK financial sanctions listings, visit OFSI’s consolidated list. Lukoil has been in the U.S. for 18 years and has gasoline stations in 11 states. This website uses cookies. OFAC has also issued a new FAQ 815 to clarify application of the 30 day quasi-wind-down period. subsidiaries. On September 12, 2014, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s Bureau of Industry and Security (BIS) again expanded their Ukraine-related sanctions and export restrictions against entities in Russia’s energy, financial services and defense sectors. Originally the SSI sanctions were implemented under two directives issued on July 16, 2014. Certain Russian and Ukrainian persons have been added to the OFAC SDN list and, as such, the property or interests in property of the listed persons that are in … 2 Operating teams are organized with a reporting line to the CEO independent of Trading. They are based in our main trading hubs, Geneva, Rotterdam, Singapore, New York, Houston, Hamburg and Dubai.Operators are pivotal to the LITASCO execution … Bryan Cave Leighton Paisner (Bryan Cave) prev. 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