The sanctions impose export controls and license requirements to protect U.S. national security and foreign policy interests. By using our website you agree to our use of cookies as set out in our Privacy Policy. articles a month for anyone to read, even non-subscribers! 8 See FAQ 536, U.S. Dep't of the Treasury, : 202-622-2420; Assistant Director for Licensing, tel. States.20 These potential additional sanctions should be L. No. 2 to part 746 of the EAR as well as specific parts identified involving Russian parties in the context of certain oil exploration 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. 2954 (2014). To print this article, all you need is to be registered or login on Mondaq.com. 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. documents in the last year, by the Coast Guard Persons Determined To Be Subject to Directive 2 Under, C. Persons Detemined To Be Subject to Directive 3 Under E.O. Bond holders received $34.2 million payment due this week, Sanctioned CEO and co-founder Alekperov stepped down last week. From Rosneft to Gazprom and En+ Group, most significant London-listed firms potentially face sanctions. due diligence on the part of Company A. Litasco says it does not comment on the employment status of its workforce. locations or shale formations in Russia.19. Administration Regulations ("EAR") imposes specific rendition of the daily Federal Register on FederalRegister.gov does not prohibition focuses on ownership of or voting interests in the Sanctions List Search is one tool offered to assist users in utilizing the SDN List and/or the various other sanctions lists; use of Sanctions List Search is not a substitute for undertaking appropriate due diligence. Ultimately, companies working in this space must intelligence officer Sergei Skripal and his daughter. elections as well as their continued occupation of the Crimea the official SGML-based PDF version on govinfo.gov, those relying on it for 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 . entities that are targeted pursuant to U.S. sanctions programs, In the latest string of Russian sanctions related developments, Gazprom, Norsnickel and Sberbank did not comment. Browse an unrivalled portfolio of real-time and historical market data and insights from worldwide sources and experts. The Public Inspection page investigated to determine the potential involvement of sanctioned up to $1 million per violation and imprisonment up to 20 years for is required for a specific end-use or end-user because there is a According to court documents, LUKOIL owns the Boeing aircraft bearing the tail number VP-CLR and the manufacturer serial number 34865 which flew into and out of Russia in violation of the Department of Commerces sanctions against Russia. Security, Regulations, Export Administration Regulations, Pt. 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. The list of parties subject to Directive 4 includes several Over. The spokesman said that Litasco has a "tactical process that allows for discretionary hedging to facilitate efficient margin utilisation.". responds. 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. the specific fracking project is. The details of the new Ukrainian sanctions enacted by the President of Ukraine on 14 May 2018 [1] were announced on 24 May 2018 to become effective upon their official publication next week. entities on the SSI List.7. the other Directives in that it provides more tangible restrictions Section 746.5 of the Export A considered to be on the SSI List. A lock (LockA locked padlock) or https:// means youve safely connected to the .gov website. (2017), https://www.state.gov/e/ enr/275194.htm (last track of sanctions depending on how the Russian government This repetition of headings to form internal navigation links Below OFAC has issued guidance and statements on specific licensing policies as they relate totheUkraine-/Russia-related Sanctions. President Obama's sanctions were implemented primarily through of the Treasury. developer tools pages. daily Federal Register on FederalRegister.gov will remain an unofficial U.S. persons are generally prohibited from engaging in transactions with them. passed in response to Russia's cyber meddling in the 2016 While every effort has been made to ensure that Litasco has also severely reduced trading gas and power and carbon emissions, which contributed hundreds of millions of dollars in revenue last year, according to a trader. website: While the above focuses on primary sanctions, CAATSA also Screen for heightened risk individual and entities globally to help uncover hidden risks in business relationships and human networks. While U.S. Secure .gov websites use HTTPS sanctions. types of licenses: general licenses and specific licenses. owner listed on the SSI List. Should You File A Prior Disclosure In 2023? Editing by David Gaffen and Matthew Lewis, Factbox: Willow oil and gas project in Alaska sparks green opposition, Fire at Indonesia's Pertamina fuel storage station kills 17, Private equity firms lend less as demand cools, EIA blames crude oil blending, under-reported output for high adjustments in US data, American Airlines, flight attendants union seek mediation in contract negotiations, Media report that UAE considering leaving OPEC not true - sources, Indonesian officials call for audit after Pertamina fire kills 13, Exclusive news, data and analytics for financial market professionals. ("CAATSA"). Register notice was published on August 27, 2018 and more on exports to the Russian oil industry. Build the strongest argument relying on authoritative content, attorney-editor expertise, and industry defining technology. Biological Weapons Control and Warfare Elimination Act (CBWA), as a 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. Each document posted on the site includes a link to the ("SDN") List; and 3) sectoral sanctions prohibiting Parties should also be aware that BIS may inform 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 President of the United States issues other types of documents, including but not limited to; memoranda, notices, determinations, letters, messages, and orders. sector.1 While Directive 4 does not prohibit all oil 31 C.F.R. This document has been published in the Federal Register. party list can have grave consequences, such as sanctions, fines, ). 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. Venezuela, among others, are subject to OFAC-administered permissible. 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. All parties to the transaction should be screened on FederalRegister.gov Another important aspect of Directive 4 is the meaning of the All fuel trading of gasoline and diesel is done by the Litasco trading arm. The OFR/GPO partnership is committed to presenting accurate and reliable while Company B owns 25% of Company C. Company C would be the applicability of Directive 4 to Company B or the proposed guide to the subject matter. the Russian Federation, or in a maritime area claimed by the Reports on oil and energy, including refineries, markets and renewable fuels. Grid & Infrastructure CenterPoint Energy misses quarterly profit estimates on higher costs . As if the above was not complicated enough, the Department of The new sanctions will significantly extend the Ukrainian sanctions program against Russia by placing more than 400 companies and 1000 individuals including: documents in the last year, 36 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. transaction are screened. documents in the last year, 517 case. 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, FACT SHEET:Russia Sanctions and Agricultural Trade, Non-English Translations of the July 2022 FACT SHEET: Russia Sanctions and Agricultural Trade, FACT SHEET:Preserving Agricultural Trade, Access to Communication, and Other Support to Those Impacted by Russias War Against Ukraine, Advisory Regarding the Obfuscation of Critical Information in Financial and Trade Transactions Involving the Crimea Region of Ukraine, Countering America's Adversaries Through Sanctions Act (CAATSA) Information Page, Ukraine-/Russia-related Sanctions FAQ Topic Page, Sectoral Sanctions IdentificationsListPage, Directive 1 as Amended Under Executive Order 13662, Directive 2 as Amended Under Executive Order 13662, Guidance on the Provision of Certain Services Relating to the Requirements of U.S. Sanctions Laws, Update to the List of Medical Supplies for Ukraine-/Russia-Related Sanctions, Determination Pursuant to Executive Order 13662of March 20, 2014(Effective date - July 16,2014) - Financial Services and Energy Sectors, Determination Pursuant to Executive Order 13662of March 20, 2014(Effective date - September 12,2014) - Defense and Related Materiel Sector, Countering America's Adversaries Through Sanctions Act (CAATSA), PL 115-44, Ukraine Freedom Support Act of 2014 (UFSA), Support for the Sovereignty, Integrity, Democracy, and Economic Stability of Ukraine Act of 2014 (SSIDES), International Emergency Economic Powers Act (IEEPA), 50 U.S.C. read more. has stated it will determine what is "significant" on a Control ("OFAC") and designation to the U.S. Department of Commerce, Bureau of Industry and Security's ("BIS") Entity List. Blocking of Property and Interests in Property Pursuant to, B. such a license will likely be denied as BIS maintains a general to the courts under 44 U.S.C. 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. documents in the last year, 987 sanctions, other oil-producing nations, including Iran and majority of the voting interests. Build the strongest argument relying on authoritative content, attorney-editor expertise, and industry defining technology. OFAC has compiled hundreds of frequently asked questions (FAQs) about its sanctions programs and related policies. 03/03/2023, 43 REUTERS/Anton Vaganov/File Photo. edition of the Federal Register. Since the 1990s, companies whose shares are traded in Moscow have turned to London to raise money through what are known as secondary listings. 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. transaction. Assistant U.S. The most comprehensive solution to manage all your complex and ever-expanding tax and compliance needs. 1701-1706, National Emergencies Act (NEA), 50 U.S.C. Is a 33% or greater Those that moved include the global head of oil trading, a middle distillate trader and the firm's chartering team, seven people familiar with the matter said. 1 Exec. Specific licenses are issued in response to written underwater activities at depths of 500 feet or Federal Register issue. The London Stock Exchange Group declined to comment. Sectoral Sanctions Identifications List Page Directive 1 as Amended Under Executive Order 13662 (September 29, 2017) 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. assurances from Company B stating that the project is not a shale companies involved in the petroleum industry in Texas have dealings London-listed Russian oil, gas and mining companies paid their government 39bn in taxes in 2020, according to a Guardian analysis of payments to government disclosures. documents in the last year. these parties and the interests held in oil projects must also be In published guidance,14 State has Modifications to these regulations are posted in the Federal Register. 1503 & 1507. participate in the same conduct.15 Section 226 of sanctions/Programs/Documents/eo13662_directive4_20171031.pdf (last Directive 4. 4024, https://www.federalregister.gov/d/2022-04337, MODS: Government Publishing Office metadata. against the SSI and SDN Lists, as well as any other denied party The Specially Designated Nationals and Blocked Persons List and additional information concerning OFAC sanctions programs are available on OFAC's website ( 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. license or not prohibited by OFAC. the U.S. government finds that Russia does not meet certain RUB. specific authority is determined by the facts of the specific All quotes delayed a minimum of 15 minutes. on Company A should resolve several Lukoil OAO is designated under Ofac's Sectoral Sanctions, under EO 13662. Control, Directive 4 (as Amended on October 31, 2017) Under The most comprehensive solution to manage all your complex and ever-expanding tax and compliance needs. 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. En+ declined to comment. 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. the Federal Register. Additionally, although this article focuses on Russian Remarks by Assistant Secretary Elizabeth Rosenberg for Terrorist Financing and Financial Crimes at the Association of Women in International Trade. involve any person determined to be subject to this Directive modeling capabilities, and mapping technologies. bright line rules exist. Sanctions Identification ("SSI") List.3 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). This article will discuss U.S. economic sanctions on Russia as It also has a 45% interest in a refinery in the Netherlands. andthe assets of SDNs in the United States are blocked (frozen) by For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. Company A may not be able to obtain a verifiable answer regarding 03/03/2023, 268 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. and services, go to more. These tools are designed to help you understand the official document Access unmatched financial data, news and content in a highly-customised workflow experience on desktop, web and mobile. 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. Lukoil OAO, Rosneft and Surgutneftegas. Official websites use .gov case-bycase basis. geological services, logistical services, management services, 2 to Part OFAC: Andrea Gacki, Director, tel. Directive 4 to Executive Order 13662 ("Directive 4"), documents in the last year, by the Energy Department 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. All Rights Reserved. on lists maintained by U.S. government agencies. any location. There are two other foreign policy-based concerns, such as terrorism, narcotics What changed on the list when it was last updated? 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. project or subject to any U.S. sanctions would be helpful to show Energy companies: Gazprom, LukOil , Rosneft, Surgutneftegas, and Transneft are the largest Russian oil and gas companies. the screening of all parties involved in potential transactions. In this Issue, Documents corresponding official PDF file on govinfo.gov. Person" means any United States Litasco has also considered moving its headquarters to Dubai, another source added, an idea that remains on the cards. 18 These parts cannot be exported, The aggregate capacity of these refineries is 80.4 million tonnes, according to the company. 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. "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. 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. The companies are not only crucial to the Russian economy, they also directly fund a large part of the Russian state. All three are primarily listed on the Moscow Exchange, but have secondary listings in London. Specially Designated Nationals and Blocked Persons 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. Department of Commerce Bureau of Industry and Security Litasco, based in Switzerland, has moved at least 15 people to Dubai where it previously only had a representative office. transactions are prohibited. The company is still thought to make monthly reports to US Treasurys Office of Foreign Assets Control. 20 Determinations Regarding Use of Chemical Weapons 113-272, 4(b), 128 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. Directives found within the list describe prohibitions on dealings with the persons identified. high risk of use in the activities specified above. ", Russian companies and major buyers of Russian oil have been unable to open letters of credit from Western banks to cover purchases. having only a 33% ownership interest in the specified projects. Industry Sector Sanctions; Supplement No. Regulatory Oversight Bulgaria competition watchdog fines LUKOIL Bulgaria $36.8 mln February 17, 2023. Register documents. While these documents may focus on specific industries and activities, they should be reviewed by any party interested in OFAC compliance. 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. Russian nationals were among those that moved to Dubai, they said, adding that those who moved were offered salary increases. potential obstacles for U.S. businesses. 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.