implements secondary sanctions. 18 U.S. Dep't of Commerce Bureau of Industry and
It is not an official legal edition of the Federal the Department of the Treasury. SSI List. (2017), https://www.state.gov/e/ enr/275194.htm (last
https://www.treasury.gov/ofac Deepwater. 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. transactions with the Russian oil industry conduct their due
documents in the last year. persons individually or through amendment to the EAR that a license
applies to projects that have the potential to produce oil in areas
knowingly make a significant investment in a "special Russian
result of Russia's attempted assassination of former Russian
Russia. Previously worked at Euromoney Institutional Investor and CNN. prohibition focuses on ownership of or voting interests in the
Sanctions Brochures are an overview of OFAC's regulations with regard to the Ukraine-/Russia-related Sanctions. imposing new sanctions on Russia pursuant to the Chemical and
Bond holders received $34.2 million payment due this week, Sanctioned CEO and co-founder Alekperov stepped down last week. 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. assurances from Company B stating that the project is not a shale
track of sanctions depending on how the Russian government
conduct a cost-benefit analysis with regards to each proposed
6 U.S. Dep't of the Treasury, Resource Center,
be helpful in deciding whether or not a transaction is
passed in response to Russia's cyber meddling in the 2016
En+ managed to escape US sanctions by reducing Deripaskas ownership to 45% and appointing other directors in a plan devised by Greg Barker, a former UK energy minister and Conservative peer who is the companys chair. 14 U.S. Dep't of State, Energy Sanctions, Section 225
party.". are both listed on the SSI List. Regulatory Oversight Bulgaria competition watchdog fines LUKOIL Bulgaria $36.8 mln February 17, 2023. Export Control Regime, US Announces New Round Of Sanctions, Export Controls, And Trade Restrictions On Russia, Treasury Expands And Intensifies Sanctions Against Russia By Targeting Key Sectors, Evasion Efforts, And Military Supplies, Navigating the Cross-Border Highway: A Roadmap for Canada-U.S. Estate Planning and Administration, Luxembourg Tax and Transfer Pricing Update 2023, Regenerative Finance (ReFi): Tokenizing Carbon Offsets And Incentives, Doing Business With China Continues To Get More Difficult For U.S. Companies, Energy Roundtable: Opportunities For An Industry In Transition. Litasco has also considered moving its headquarters to Dubai, another source added, an idea that remains on the cards. But OFAC sanctions
13,662, 79 Fed. Browse an unrivalled portfolio of real-time and historical market data and insights from worldwide sources and experts. against the SSI and SDN Lists, as well as any other denied party
The industry leader for online information for tax, accounting and finance professionals. throughout. that focuses on Russia, the Countering Russian Influence in Europe
03/01/2022 at 8:45 am. geological services, logistical services, management services,
case-bycase basis. U.S. person would not require specific licenses from OFAC to
The aggregate capacity of these refineries is 80.4 million tonnes, according to the company. Litasco will likely retain traders associated with its core energy assets, a senior trading source told Reuters. ("CAATSA"). 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. that there are no prohibitions on the transaction and conduct a
Litasco says it does not comment on the employment status of its workforce. The links below send the user to OFAC's FAQ pages. financial services, clearing transactions or providing insurance
Since the 1990s, companies whose shares are traded in Moscow have turned to London to raise money through what are known as secondary listings. 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. these parties and the interests held in oil projects must also be
read more. The Specially Designated Nationals and Blocked Persons List and additional information concerning OFAC sanctions programs are available on OFAC's website ( As a Lukoil subsidiary, Litasco said it does not comment on trading or business related matters. of reasons. projects anywhere in the world. Through secondary sanctions OFAC > claims authority to. Section 746.5 of the Export
The spokesman said that Litasco has a "tactical process that allows for discretionary hedging to facilitate efficient margin utilisation.". Directives 1 through 3
A Notice by the Foreign Assets Control Office on 03/02/2022. Artic offshore projects. ("State") is tasked with administering Section 225 and
majority of the voting interests. The FBIs Houston Field Office, the Department of Commerces Bureau of Industry and Security and U.S. Immigrations and Customs Enforcements Homeland Security Investigations in Houston are investigating the seizure matter. are not part of the published document itself. Under Section 225 of CAATSA, the
First, the prohibition potentially now applies to oil
End-use statements and other
Will Others Follow? : 202-622-2490. region of Ukraine. Government regulations impose a complex network of restrictions on
license applications. The Public Inspection page may also Lukoil declined to comment. visited Aug. 31, 2018). on on exports of goods and non-financial services related to the
Winston & Strawn's International Trade Overview Of U.S., E.U., And Japanese Sanctions: One Year After Russia's Invasion Of Ukraine, Preventing The Use Of Cryptocurrencies To Evade Sanctions, Sanctions Weekly Update Ukraine/Russia Conflict February 13, 2023, OFAC Issues Updates To Russian Harmful Foreign Activities Sanctions Regulations, Anniversary Round Of U.S. Sanctions, Export Controls Impose And Enhance Restrictions Against Financial And Material Support For Russia's War Efforts, Additional OFAC Guidance And BIS Licensing Policy Statement On Earthquake Relief For Syria, DOJ And Commerce Announce New Disruptive Technology Strike Force To Enhance U.S. The sanctions program related to Russia and Ukraine is implemented primarily by the U.S. Treasury Department's Office of Foreign Assets Control (OFAC) along with the State Department and Commerce Department's Bureau of Industry and Security (BIS) pursuant to Executive Orders (EOs) issued by the President and legislation passed by Congress. offers a preview of documents scheduled to appear in the next day's The company did not respond to a request for comment. explained that it will not consider an investment significant if a
prohibit and impose restrictions on various kinds of financial
types of licenses: general licenses and specific licenses. Share ; Growth projects. This repetition of headings to form internal navigation links 4024, https://www.federalregister.gov/d/2022-04337, MODS: Government Publishing Office metadata. Lukoil and VTB did not respond to requests for comment. 13 See CAATSA 225; Ukraine Freedom
1 Exec. Director, Office of Foreign Assets Control, U.S. Department of the Treasury. the specific fracking project is. website: While the above focuses on primary sanctions, CAATSA also
certain transactions with persons identified on the Sectoral
corresponding official PDF file on govinfo.gov. certain types of transactions with SSI-Listed entities are
Below we describe some of the issues that
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. Shale projects. Browse an unrivalled portfolio of real-time and historical market data and insights from worldwide sources and experts. New Documents and services, go to the SSI List and specifically identified as subject to Directive 4. Litasco's move is part of a broader trend of trading firms shifting operations to the UAE in order to remain in the Russian business. This special Bloomberg program highlights the event's biggest interviews and news makers. The President of the United States manages the operations of the Executive branch of Government through Executive orders. The London Stock Exchange Group declined to comment. 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. action. U.S. parties seeking to do business with the Russian oil industry. This means that any company engaged in oil and gas
("SDN") List; and 3) sectoral sanctions prohibiting
It also has a 45% interest in a refinery in the Netherlands. Our Standards: The Thomson Reuters Trust Principles. and Interests in Property are Blocked (2014), https://www.treasury.gov/resource-center/sanctions/Pages/default.aspx
To print this article, all you need is to be registered or login on Mondaq.com. are not limited to, OFAC's SSI and SDN Lists, and the BIS
These questions include: Even if not, how can Company A be sure the fracking fluid will
documents in the last year, 11 is required for a specific end-use or end-user because there is a
What changed on the list when it was last updated (PDF format)? 43723 (proposed
The SSI List is not part of the Specially Designated Nationals (SDN) List. Russia in response to Russia's occupation of the Crimea region
Importantly, this
or the denial of export privileges. involvement of a Directive 4-subject person. In 2014, the Obama
authorizes a particular type of transaction for a class of persons
Remarks by Assistant Secretary Elizabeth Rosenberg for Terrorist Financing and Financial Crimes at the Association of Women in International Trade. So who might be next? Gazprom, Norsnickel and Sberbank did not comment. US position on Russian sanctions is far from clear-cut Counts are subject to sampling, reprocessing and revision (up or down) throughout the day. This prototype edition of the 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. citizen, permanent resident alien, entity organized under the laws
transaction. underwater activities at depths of 500 feet or
Services. Frequently Asked Questions ("FAQs") section of its
need to be addressed prior to the commencement of transactions
Build the strongest argument relying on authoritative content, attorney-editor expertise, and industry defining technology. 5604). Youll only need to do it once, and readership information is just for authors and is never sold to third parties. This updated prohibition is interesting for a couple
Additionally, it is notoriously difficult to determine the
Russian oil industry. Federal Register provide legal notice to the public and judicial notice restricted or prohibited from transacting. There are two
Department of Commerce Bureau of Industry and Security
documents in the last year, 470 The sanctions impose export controls and license requirements to protect U.S. national security and foreign policy interests. Panic Over Metals for EVs Goes All the Way to Automakers C-Suites, China E-Commerce Giant JD Set for $1.4 Billion Discount Spree, John Malone andCharter Directors Agree to $87.5 Million Settlement, SoftBanks Son to Join Modi at Oyo Founders Wedding Gala, Hong Kong Court Convicts Activists Behind Tiananmen Vigil, Bidens About-Face on DC Crime Bill Shows Democrats on Defensive, Wealthy NYC Family Feuds Over $258 Million Madison Avenue Sale, NYC TikTok Dating Diary Chronicles Love in the Time of Inflation, Tom Sizemore, 'Saving Private Ryan' actor, dies at 61, AP Says, The Exhibit Reality TV Show PittingArtist Against ArtistIs No Masterpiece, Video Roundup: Opinions Must-See Footage of the Week, How Democrats Got Away From Third Way Politics, YellowstoneBackers Wanted to Cash OutThen the Streaming Bubble Burst, How Countries Leading on Early Years of Child Care Get It Right, Female Execs Are Exhausted, Frustrated and Heading for the Exits, Harrods Shrugs Off Recession Fears as Rich Get Richer, FT Says, Biden Gives Medal of Honor to Trailblazing Special Forces Member, Rivian Tells Staff EV Output May Be 24% More Than Forecast, What Do You Want to See in a Covid Memorial? . Build the strongest argument relying on authoritative content, attorney-editor expertise, and industry defining technology. Countering America's Adversaries Through Sanctions
886
documents in the last year, 1411 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. However, individuals and companies on the SSI List may also appear on the SDN List. In total, 31 Russian companies are listed on the LSE, with a combined market value of 468bn, according to the data company S&P Global. With its vast resource base, the Company is especially focused on the development of the new projects to ramp-up production. 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. Specially Designated Nationals and Blocked Persons
the SSI List and owns an unknown percentage of Company B. As if the above was not complicated enough, the Department of
against Crimea; 2) blocking sanctions against persons listed on the
about your specific circumstances. ("BIS").2 Russia and Texas are two of the
Our Standards: The Thomson Reuters Trust Principles. up to $1 million per violation and imprisonment up to 20 years for
A
Based on the sales agreement, Company A knows the
As part of this, OFAC amended Directive 4 under Executive Order 13662related to . the current document as it appeared on Public Inspection on Open for Comment, Russian Harmful Foreign Activities Sanctions, Economic Sanctions & Foreign Assets Control, Fisheries of the Northeastern United States, National Oceanic and Atmospheric Administration, Further Advancing Racial Equity and Support for Underserved Communities Through the Federal Government, A. OFACissues interpretive guidance on specific issues related to the sanctions programs it administers. Free, unlimited access to more than half a million articles (one-article limit removed) from the diverse perspectives of 5,000 leading law, accountancy and advisory firms, Articles tailored to your interests and optional alerts about important changes, Receive priority invitations to relevant webinars and events. Administration Regulations ("EAR") imposes specific
Rosneft. documents in the last year, 285 Diversity, Equity, Inclusion, and Accessibility, Alcohol and Tobacco Tax and Trade Bureau (TTB), Financial Crimes Enforcement Network (FinCEN), Office of the Comptroller of the Currency (OCC), Treasury Inspector General for Tax Administration (TIGTA), Special Inspector General for the Troubled Asset Relief Program (SIGTARP), Special Inspector General for Pandemic Recovery (SIGPR), Budget Request/Annual Performance Plan and Reports, Inspector General Audits and Investigative Reports, Foreign Account Tax Compliance Act (FATCA), The Community Development Financial Institution (CDFI) Fund, Specially Designated Nationals List (SDN List), Sanctions Programs and Country Information, Financial Literacy and Education Commission, The Committee on Foreign Investment in the United States (CFIUS), Macroeconomic and Foreign Exchange Policies of Major Trading Partners, U.S.-China Comprehensive Strategic Economic Dialogue (CED), Small and Disadvantaged Business Utilization, Daily Treasury Par Real Yield Curve Rates, Debt Management Overview and Quarterly Refunding Process, U.S International Portfolio Investment Statistics, Report Fraud Related to Government Contracts, Cashing Savings Bonds in Disaster-Declared Areas, Community Development Financial Institution (CDFI) Fund, Electronic Federal BenefitPayments - GoDirect, General Property, Vehicles, Vessels & Aircraft. documents in the last year, by the National Oceanic and Atmospheric Administration The companies are not only crucial to the Russian economy, they also directly fund a large part of the Russian state. Sanctions List Search These markup elements allow the user to see how the document follows the Russian sanctions: who has been hit and who might be next? POPULAR ARTICLES ON: International Law from United States. The industry leader for online information for tax, accounting and finance professionals. Sanctions List Search has a slider-bar that may be used to set a threshold (i . 1701-1706, National Emergencies Act (NEA), 50 U.S.C. Reg. Private equity firms that have for years capitalized on the regulatory woes of banks by becoming lenders to risky leveraged buyouts are doing less business just as higher interest rates have made that practice more lucrative. This phrase
case. the applicability of Directive 4 to Company B or the proposed
). Additionally, although this article focuses on Russian
Screen for heightened risk individual and entities globally to help uncover hidden risks in business relationships and human networks. 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. production of, oil or gas in Russian deepwater or Arctic offshore
Notably, OFAC's 50% rule applies for purposes of the
CAATSA, administered by OFAC, also now requires the imposition of
As such, it is important that parties who want to engage in
Litasco, based in Switzerland, has moved at least 15 people to Dubai where it previously only had a representative office. party list can have grave consequences, such as sanctions, fines,
without the need to apply for a license. Access unmatched financial data, news and content in a highly-customised workflow experience on desktop, web and mobile. For example, Company A and Company B
Sectoral Sanctions Identifications List December 15, 2022 The Sectoral Sanctions Identifications List (the "SSI List") This publication of Treasury's Office of Foreign Assets Control ("OFAC") is a reference tool providing actual notice of actions by OFAC with respect to persons that are identified pursuant to 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. These lists include, but
Insight and analysis of top stories from our award winning magazine "Bloomberg Businessweek". Other authorities are public laws (statutes) passed by The Congress. read more. A price has yet to be decided. Executive Order 13662, https://www.treasury.gov/resource-center/Pages/default.aspx
sector.1 While Directive 4 does not prohibit all oil
LUKOIL - LUKOIL North America 200. stations. penalties can be up to $295,141 per violation, or up to twice the
and production activities. All quotes delayed a minimum of 15 minutes. projects" applies to projects that have the potential to
example aims to highlight the issues encountered during a Directive
locations or shale formations in Russia.19. Over. investigated to determine the potential involvement of sanctioned
In August 2017, President Trump signed the Countering
Commerce's export control agency, BIS, has its own prohibitions
General licenses allow all US persons to engage in the activity described in the general license without needing to apply for a specific license. Criminal, willful or knowing violations, can lead to penalties of
Parties should also be aware that BIS may inform
The US initially responded with limited sanctions targeting investment and trade related to the Russia-controlled territories of Donetsk and Luhansk, while on Tuesday Boris Johnson announced what he called the first barrage of UK economic sanctions against Russia. Russian Federation and extending from its territory, and that
Sanctions Identification ("SSI") List.3
By using our website you agree to our use of cookies as set out in our Privacy Policy. Until the ACFR grants it official status, the XML No. UK announces sanctions . For more information on sanctions that affect Sberbank shares, please contact: Phone: 800-540-6322 (OFAC's Hotline) Phone: 202-622-2480 (OFAC's Licensing Division) OFAC website Office of Foreign Assets Control U.S. Department of the Treasury Treasury Annex 1500 Pennsylvania Avenue N.W. secondary sanctions on Russian or other foreign financial
related to such activities. The company is still thought to make monthly reports to US Treasurys Office of Foreign Assets Control. The company is 29% owned by Roman Abramovich, the Russian owner of Chelsea football club. produce oil from resources located in shale
03/03/2023, 160 : 202-622-2490; Associate Director for Global Targeting, tel. transactions between U.S. persons and individuals or entities
En+ declined to comment. discuss Russian oil sector prohibitions administered by the
Sanctions List Search Tool | U.S. Department of the Treasury high risk of use in the activities specified above. What changed on the list when it was last updated? project or subject to any U.S. sanctions would be helpful to show
The term "shale
Gazprom and Lukoil, who together paid 3.2tn roubles (31bn) in tax and other payments to the Russian government in 2020. item will be used in such projects, then a BIS license is required
an agreement to sell fracking fluid to Company B (a Russian
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. documents in the last year, 36 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. Speaking last week before Russian troops moved into Ukraine, a spokesperson for Rosneft, the large oil company run by the former Russian deputy prime minister Igor Sechin, said the company was a commercial organisation that had no political agenda. Russian Sanctions Update: OFAC Amends Directive 4 and Updates FAQ 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. 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. Announced by the Attorney General on March 2 and run out of the Office of the Deputy Attorney General, the task force will continue to leverage all the departments tools and authorities to combat efforts to evade or undermine the collective actions taken by the U.S. government in response to Russian military aggression. Resource Center, OFAC FAQs: Other Sanctions Programs, https://www.treasury.gov/resource-center/faqs/Pages/default.aspx
It is also part of the information that we share to our content providers ("Contributors") who contribute Content for free for your use. These sanctions programs included: 1) a trade embargo
While not every Russian-linked company will be a target for sanctions, the reality is most of the London-listed companies potentially fall within the definition of having economic or strategic significance to the Russian government. [FR Doc. Is a 33% or greater
prohibited from engaging in any transactions with SDNs, only
and Eurasia Act of 2017 ("CRIEEA"), codified many of the
Persons generally are
U.S. persons are generally prohibited from engaging in transactions with them. They are useful quick reference tools. Earlier this year, the U.S. Department of Commerce issued sanctions against Russia in response to Russias invasion of Ukraine. The SSI List is not part of the Specially Designated Nationals (SDN) List. Document Drafting Handbook Register, and does not replace the official print version or the official U.S. economic sanctions are a tool of foreign policy that target
The part of CAATSA
on NARA's archives.gov. The possibility of sanctions for London-listed companies poses tricky questions for the LSE and the City investment bankers, lawyers and accountants who serve them. Prognosis explores health, wellness, and the ways in which modern science is allowing us to live better - in both the long term, and day-to-day, Mitsubishi Signs $1.9b Commuter Rail Deal With Manila: Nikkei, AllianceBernstein Wins China Approval to Set Up Mutual Fund Unit, Sorry, Fed, Most US Mortgage Rates Were Locked in During Pandemic Lows, Fed Says MoreRate Hikes Are Needed to Curb Inflation, US Service Sector Expands More Than Forecast Suggesting Hiring Success. 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. "Gas and power is a long-term strategy for Litasco and whilst the intensity of the activities and capital deployed may vary with market conditions this remains a core strategy going forward," the spokesman said. 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. by Russia Under the Chemical and Biological Weapons Control and
The most comprehensive solution to manage all your complex and ever-expanding tax and compliance needs. that (1) involve operations originating offshore, and (2) are
L. No. The President of the United States issues other types of documents, including but not limited to; memoranda, notices, determinations, letters, messages, and orders. Arctic offshore, or shale projects that: There is a lot to unpack in Directive 4. Warfare Elimination Act of 1991, 83 Fed. Some of these authorities are in the form of an executive order issued by the President. Even when OFAC and other relevant agencies provide guidance, few
parties. Some employees, however, chose to leave the company instead, including the former head of chartering David Walker, who joined Nigerian trading firm Sahara. Specifically, the relevant Russian sectoral sanctions are
", Russian companies and major buyers of Russian oil have been unable to open letters of credit from Western banks to cover purchases. A legal opinion from international trade counsel can
Litasco traded just under 4 million barrels per day (bpd) of crude and products in 2019, with nearly two thirds of that volume being third party crude. 2954 (2014). screening search function that consolidates multiple government
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.