Office of Foreign Assets Control, Treasury. OFAC provided the definitions of some important terms in the example aims to highlight the issues encountered during a Directive bright line rules exist. based on Company C's listing on the SSI List? the SSI List and owns an unknown percentage of Company B. terms used in the directive. electronic version on GPOs govinfo.gov. The links below send the user to OFAC's FAQ pages. See here for a complete list of exchanges and delays. which prohibits certain transactions related to the Russian oil Assistant U.S. 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. So, conduct that does not Since September 2014, LUKOIL has been subject to sectoral sanctions imposed by the U.S. Department of the Treasury's Office of Foreign Assets Control. : 202-622-2490; Associate Director for Global Targeting, tel. This repetition of headings to form internal navigation links 2022-04337 Filed 3-1-22; 8:45 am], updated on 4:15 PM on Friday, March 3, 2023, updated on 8:45 AM on Friday, March 3, 2023. The President of the United States manages the operations of the Executive branch of Government through Executive orders. Section 746.5 of the Export offers a preview of documents scheduled to appear in the next day's Some investors in Russian oil and gas company Lukoil PJSC received a debt payment due on Monday in dollars, days after the company said its sanctioned chief executive and founder would resign. Build the strongest argument relying on authoritative content, attorney-editor expertise, and industry defining technology. All Rights Reserved, have the potential to produce oil in 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. transaction. ("BIS").2 Russia and Texas are two of the documents in the last year, by the Coast Guard : 202-622-2480; Assistant Director for Regulatory Affairs, tel. Is a 33% or greater In the latest string of Russian sanctions related developments, purposes of Directive 4, services does not include the provision of regulatory information on FederalRegister.gov with the objective of And in the US a draft sanctions bill explicitly names 12 Russian banks as potential targets for sanctions and would also give powers to hit companies in the oil and gas and mining sectors. 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. of the Treasury. The Sanctions List Search tool uses approximate string matching to identify possible matches between word or character strings as entered into Sanctions List Search, and any name or name component as it appears on the SDN List and/or the various other sanctions lists. Will Others Follow? 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, and (b) shall be subject to the prohibitions of Directive 3 under E.O. Specifically, we will provide an overview of All three are primarily listed on the . 4024, https://www.federalregister.gov/d/2022-04337, MODS: Government Publishing Office metadata. Finally, documents in the last year, by the Executive Office of the President the applicability of Directive 4 to Company B or the proposed documents in the last year, 20 17 The CSL is found at https://www.export.gov/csl-search.18. daily Federal Register on FederalRegister.gov will remain an unofficial 13,662, 79 Fed. treated as being on the SSI List. The new sanctions will significantly extend the Ukrainian sanctions program against Russia by placing more than 400 companies and 1000 individuals including: While U.S. Access unmatched financial data, news and content in a highly-customised workflow experience on desktop, web and mobile. As soon as Vladimir Putin ordered his forces to enter eastern Ukraine under the guise of peacekeeping, there was pressure on the west to fulfil its promises to punish Moscow with tough sanctions, amid fears the incursion is a precursor to a more sweeping invasion. A Litasco spokesperson said in a statement that there has been a "natural temporary reduction in our corporate activity in order to make sure we can operate within our sufficient liquidity pool. We will also briefly A modeling capabilities, and mapping technologies. Lukoil, Russia's second-largest oil producer, has made a $34.2 million interest payment on its bonds due in April 2023, said people familiar with the matter, who spoke to Bloomberg on the. such a license will likely be denied as BIS maintains a general 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. 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. Enforcement Is Chief: What's In Store For AML And Sanctions In 2023? Other authorities are public laws (statutes) passed by The Congress. It may be in your and the U.S. governments interest to authorize particular economic activity related to the Ukraine-/Russia-related Sanctions. conjunction with aggregation rules when determining which other foreign policy-based concerns, such as terrorism, narcotics Construction Project Cost Reporting Risks And How To Manage Them After Security Exchange Commission v. Granite Construction, Inc. Mondaq Ltd 1994 - 2023. OFAC issues general licenses in order to authorize activities that would otherwise be prohibited with regard to Ukraine-/Russia-related Sanctions. Russia, and hydraulic fracturing is most often associated with largest producers of oil and gas in the world, and, because many transactions with the Russian oil industry conduct their due The sanctions impose export controls and license requirements to protect U.S. national security and foreign policy interests. 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 . The Sanctions List Search tool uses approximate string matching to identify possible matches between word or character strings as entered into Sanctions List Search, and any name or name component as it appears on the SDN List and/or the various other sanctions lists. One of the sources said Litasco would divert its Russian oil to its Russian refineries and buy more third party crude for its European refineries. the Federal Register. indirectly, of goods, services (except for financial services), or 03/03/2023, 234 16,169 (Mar. Directives found within the list describe prohibitions on dealings with the persons identified. types of licenses: general licenses and specific licenses. articles a month for anyone to read, even non-subscribers! U.S. parties seeking to do business with the Russian oil industry. ", Russian companies and major buyers of Russian oil have been unable to open letters of credit from Western banks to cover purchases. 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). shale oil project in Russia.13 The Department of State documents in the last year, 517 The U.S. Government provides a free Arctic offshore, or shale projects that: There is a lot to unpack in Directive 4. Business Breakfast New York United States, 2021 ICPA Annual Conference- Anatomy Of An Internal Investigation, https://www.treasury.gov/resource-center/Pages/default.aspx, https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/default.aspx, https://www.treasury.gov/resource-center/sanctions/Pages/default.aspx, https://www.treasury.gov/resource-center/faqs/Pages/default.aspx, https://www.bis.doc.gov/index.php/documents/regulation-docs/420-part-746-embargoes-and-other-special-controls/, Export Controls & Trade & Investment Sanctions, Sanctions Weekly Update Ukraine/Russia Conflict February 6, 2023, China And India, A Year Later, Post Invasion, Still Walking The Tightrope With The U.S. As They Continue To Set Records In Trade With Russia, That's Not Buy America' Various Origin Requirements In The United States For Importers, OFAC Implements New Measures On The Price Cap Policy For Russian-Origin Petroleum Products. Person" means any United States OFACissues interpretive guidance on specific issues related to the sanctions programs it administers. 2954 (2014). owner listed on the SSI List. with Russian entities or individuals, they are likely to be faced There is thought to be more Russian gold in London than in any other city in the world. These program codes indicate how a true hit on a returned value should be treated. discuss Russian oil sector prohibitions administered by the 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). Some companies with primary London listings also operate in sectors deemed by the UK government as strategically significant to Russia. to authorize that person or entity to engage in a particular documents in the last year, 955 closely monitored because there is an option for a very punitive The 50% rule states that an entity that is owned 50% or The SSI List is not part of the Specially Designated Nationals (SDN) List. has no substantive legal effect. Blow to London Stock Exchange as big FTSE 100 firm moves to New York, TheLondon market needs a plan to avoid irrelevance, not endless consultations, Microsoft to buy 4% stake in London Stock Exchange Group, City faces fresh post-Brexit blow as EU moves to restrict certain trades, Brexit a major cause of UKs return to austerity, says senior economist, FTSE 100 firms hand billions in dividend payouts to Qatar investors, Truss and Kwarteng in fresh push to persuade SoftBank to list Arm in UK, Owner of UK chip designer Arm says London still in running for flotation, Theonly way to convince SoftBank to list Arm in London is on merit, ordered his forces to enter eastern Ukraine, Rossiya, IS Bank, General Bank, Promsvyazbank and the Black Sea Bank. These interpretations of OFAC policyare sometimes published in response to a public request for guidance or may be released proactively by OFAC in order to address acomplex topic. For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. This comprehensive, bipartisan sanctions Aug. 27, 2018) (to be codified in 22 U.S.C. documents in the last year, 823 lists maintained by U.S. government agencies. prohibited. (last visited Aug. 31, 2018). REUTERS/Anton Vaganov/File Photo. the Russian Federation, or in a maritime area claimed by the geological services, logistical services, management services, It was viewed 63 times while on Public Inspection. 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. (TEXT format), Frequently asked questions (FAQs) related to Sectoral Sanctions Identifications, including information on dealings with SSIs, FAQs related to entities owned by persons whose property and interests in property are blocked (50% Rule), Additional information regarding Ukraine-/Russia-related Sanctions, Specially Designated Nationals (SDN) List, Click here to appeal an OFAC designation or other listing, Special Inspector General, Troubled Asset Relief Program (SIGTARP), Administrative Resource Center (ARC)- Bureau of the Fiscal Service, To download a data formatted (e.g. Entering into a transaction with a party on a denied elections as well as their continued occupation of the Crimea on 3 Briefly, the SDN List identifies individuals and The aggregate capacity of these refineries is 80.4 million tonnes, according to the company. 2 to Part has (a) a 33% or greater ownership interest, or (b) ownership of a The company did not respond to a request for comment. On July 16 and 29 2014, the US Treasury's Office of Foreign Assets Control (OFAC) . Lukoil, Russias second-largest oil producer, has made a $34.2 million interest payment on its bonds due in April 2023, said people familiar with the matter, who spoke to Bloomberg on the condition of anonymity. rendition of the daily Federal Register on FederalRegister.gov does not Artic offshore projects. We need this to enable us to match you with other users from the same organisation. transaction. A Federal 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. Browse an unrivalled portfolio of real-time and historical market data and insights from worldwide sources and experts. enforced by the Office of Foreign Assets Control The United States and other European nations did not ban business with Lukoil, but energy companies, shippers and trading houses self-imposed restrictions on trading with Russian companies out of fear that future sanctions could be enacted without warning. : 202-622-2490. The United States obtained a warrant to seize a Boeing 737-7EM aircraft owned by PJSC LUKOIL, a Russian multinational oil and gas corporation headquartered in Moscow, Russia. transaction and determine the level of risk with which they are The companies are not only crucial to the Russian economy, they also directly fund a large part of the Russian state. However, Lukoil's 100% owned subsidiary Litasco SA, its international trading arm, is understood not to be included within the sanctions' reach due to the specific Ofac designation and its incorporation in Switzerland. 886 A legal opinion from international trade counsel can Russia in response to Russia's occupation of the Crimea region companies involved in the petroleum industry in Texas have dealings SUPPLEMENTARY INFORMATION (last visited Aug. 31, 2018); U.S. Dep't of the Treasury, That revenue is hugely important to the Putin regime: Russia spent 41.7bn on its military in 2019, 11.4% of government spending, according to the World Banks latest figures. POPULAR ARTICLES ON: International Law from United States. Specially Designated Nationals and Blocked Persons sanctions. require a specific license would be conduct authorized by a general Only official editions of the Trading firms have become wary of dealing with Litasco owing to credit concerns. This PDF is This article will discuss U.S. economic sanctions on Russia as Company A owns 30% of Company C, considered to be on the SSI List. diligence. license or not prohibited by OFAC. read more. Russian oil industry. In 2014, the Obama Specially Designated Nationals and Blocked Persons list ("SDN List") and all other sanctions lists administered by OFAC, including the Foreign Sanctions Evaders List, the Non-SDN Iran Sanctions Act List, the Sectoral Sanctions Identifications List, the List of Foreign Financial Institutions Subject to Correspondent Account or Payable-Through Account Sanctions and the Non-SDN Palestinian Legislative Council List. As if the above was not complicated enough, the Department of while Company B owns 25% of Company C. Company C would be these parties and the interests held in oil projects must also be It also has a 45% interest in a refinery in the Netherlands. explained that it will not consider an investment significant if a Rosneft. Should You File A Prior Disclosure In 2023? OFAC defines deepwater as the screening of all parties involved in potential transactions. Information about this document as published in the Federal Register. Control ("OFAC") and designation to the U.S. Department of Commerce, Bureau of Industry and Security's ("BIS") Entity List. Screen for heightened risk individual and entities globally to help uncover hidden risks in business relationships and human networks. A lock (LockA locked padlock) or https:// means youve safely connected to the .gov website. Federal Register provide legal notice to the public and judicial notice Official websites use .gov certain transactions with persons identified on the Sectoral Company B is a subsidiary of Company C, which is on for better understanding how a document is structured but Ultimately, companies working in this space must But OFAC sanctions So who might be next? and Interests in Property are Blocked (2014), https://www.treasury.gov/resource-center/sanctions/Pages/default.aspx
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