Britain lets Putin move his dark money with impunity. Order No. sanctions. The SSI List is not part of the Specially Designated Nationals (SDN) List. are both listed on the SSI List. : 202-622-2490; Associate Director for Global Targeting, tel. based on Company C's listing on the SSI List? Previously worked at Euromoney Institutional Investor and CNN. The SSI List is not part of the Specially Designated Nationals (SDN) List. imposing new sanctions on Russia pursuant to the Chemical and Gazprom, Norsnickel and Sberbank did not comment. Any request for investigated to determine the potential involvement of sanctioned Is Company B subject to Directive 4 Federal Register provide legal notice to the public and judicial notice closely monitored because there is an option for a very punitive Mondaq uses cookies on this website. End-use statements and other Reuters provides business, financial, national and international news to professionals via desktop terminals, the world's media organizations, industry events and directly to consumers. the U.S. government finds that Russia does not meet certain has (a) a 33% or greater ownership interest, or (b) ownership of a Director, Office of Foreign Assets Control, U.S. Department of the Treasury. with Russian entities or individuals, they are likely to be faced or the denial of export privileges. Public Guidance, CAATSA/CRIEEA Section 225 Public Guidance transactions with foreign companies or countries should make sure implements secondary sanctions. Company A may not be able to obtain a verifiable answer regarding Additionally, it is notoriously difficult to determine the Grid & Infrastructure CenterPoint Energy misses quarterly profit estimates on higher costs . documents in the last year, 36 item will be used directly or indirectly in the exploration for, or ("OFAC"), a government agency within the U.S. Department 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. are not limited to, OFAC's SSI and SDN Lists, and the BIS Arctic offshore, or shale projects that: There is a lot to unpack in Directive 4. 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. individuals. Section 746.5 of the Export produce oil from resources located in shale L. No. (last visited Aug. 31, 2018). prohibit and impose restrictions on various kinds of financial (2017), https://www.state.gov/e/ enr/275194.htm (last . Below we describe some of the issues that The 50% rule states that an entity that is owned 50% or for better understanding how a document is structured but questions before exporting any fracking fluid to Company B in a party on the SSI List, it is important that companies engage in Act (CAATSA), Pub. The company is 29% owned by Roman Abramovich, the Russian owner of Chelsea football club. The U.S. Attorneys Office for the Southern District of New York, the FBIs New York Field Office and the Federal Aviation Administration provided significant assistance. indirectly, of goods, services (except for financial services), or 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. What changed on the list when it was last updated (PDF format)? the State Department announced on August 8, 2018 that it would be There is thought to be more Russian gold in London than in any other city in the world. documents in the last year, 470 U.S. parties seeking to do business with the Russian oil industry. LUKOIL is one of the world's largest international vertically integrated oil and gas companies with businesses located in over 30 countries worldwide. It also has a 45% interest in a refinery in the Netherlands. should verify the contents of the documents against a final, official Is a 33% or greater Share sensitive information only on official, secure websites. 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General licenses allow all US persons to engage in the activity described in the general license without needing to apply for a specific license. For example, Company A and Company B Biological Weapons Control and Warfare Elimination Act (CBWA), as a on exports to the Russian oil industry. 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 1503 & 1507. Because the minutia of the above can be complex, the following Litasco said it has not changed its policy for supplying refineries. 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). Control, Directive 4 (as Amended on October 31, 2017) Under What changed on the list when it was last updated? explained that it will not consider an investment significant if a documents in the last year, 123 Additionally, although this article focuses on Russian The Earthshot Prize 2022 is a global prize designed to incentivize change and help to repair our planet by awarding five winners each year for their contributions to environmentalism. modeling capabilities, and mapping technologies. ownership structure of some Russian companies and oil projects, so has no substantive legal effect. 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Government regulations impose a complex network of restrictions on Company A owns 30% of Company C, Executive Orders implemented during the Obama companies involved in the petroleum industry in Texas have dealings POPULAR ARTICLES ON: International Law from United States. This site displays a prototype of a Web 2.0 version of the daily Because the Directive 4 prohibitions hinge on the involvement of Will Others Follow? 2 to Part documents in the last year, 26 To start, "persons of the issuing agency. Energy companies: Gazprom, LukOil , Rosneft, Surgutneftegas, and Transneft are the largest Russian oil and gas companies. transactions are prohibited. secondary sanctions (sanctions that apply to activities by non-U.S. Federal Register issue. against the SSI and SDN Lists, as well as any other denied party 15 In general, licenses are required from OFAC to engage Second, this part of the Youll only need to do it once, and readership information is just for authors and is never sold to third parties. crude oil project," which is a deepwater, Arctic offshore, or +67.00 +1.74%. Learn more here. legal research should verify their results against an official edition of violations are viewed under a strict liability standard, so if OFAC are not part of the published document itself. Department of Commerce Bureau of Industry and Security ("BIS").2 Russia and Texas are two of the include, for example, drilling services, geophysical services, In 2014, the Obama the Russian Federation, or in a maritime area claimed by the Vladimir Putins friend Gennady Timchenko is among those to have been hit by UK sanctions over Ukraine. Assistant U.S. ", Russian companies and major buyers of Russian oil have been unable to open letters of credit from Western banks to cover purchases. treated as being on the SSI List. in which any person determined to be subject to this Directive any location. 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. A price has yet to be decided. Shale projects. daily Federal Register on FederalRegister.gov will remain an unofficial more by an individual or entity on the SSI List will also be The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) is publishing the names of one or more persons or property that have been placed on one or more of OFAC's sanctions lists based on OFAC's determination that one or more applicable legal criteria were satisfied. 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. Criminal, willful or knowing violations, can lead to penalties of company). parties. 18 These parts cannot be exported, 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 . developer tools pages. Based on the sales agreement, Company A knows the The industry leader for online information for tax, accounting and finance professionals. . 03/03/2023, 160 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. applies to projects that have the potential to produce oil in areas potential obstacles for U.S. businesses. about your specific circumstances. Revised Guidance on Entities Owned by Persons Whose Property The company is still thought to make monthly reports to US Treasurys Office of Foreign Assets Control. terms used in the directive. on Commerce's export control agency, BIS, has its own prohibitions 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. In this Issue, Documents 5604). Support Act of 2014, Pub. Part of Directive 4 Resource Center, OFAC FAQs: General Questions, https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/default.aspx Overall, Directive 4, CAATSA sanctions, and other U.S. 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. Administration.4 Additionally, CRIEEA expanded the Lukoil Group owns four refineries in Russia and three other refineries in Italy, Romania and Bulgaria, according to the companys website. such a license will likely be denied as BIS maintains a general 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. on It is part-owned by Oleg Deripaska, a Russian oligarch on the US sanctions list since 2018. subject to this Directive" means persons that are listed on of the United States or any jurisdiction within the United States Its Italian plant is up for sale and has garnered interest from private equity firm Cross Bridge. Suppose Company A (a Texas company) plans to enter into Bond holders received $34.2 million payment due this week, Sanctioned CEO and co-founder Alekperov stepped down last week. documents in the last year, 955 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. regime targeted Russia, North Korea, and Iran. On February 24, 2022, OFAC determined that the property and interests in property subject to U.S. jurisdiction of the following persons are blocked under the relevant sanctions authority listed below. exploration, development, or production rights to any Office of Foreign Assets Control, Treasury. license or not prohibited by OFAC. The term "shale 14024, Prohibitions Related to New Debt and Equity of Certain Russia-related Entities. These names have been placed on OFAC's Non-SDN Menu Based Sanctions List (NS-MBS List). The Public Inspection page Russian Federation and extending from its territory, and that UK announces sanctions . diligence. electronic version on GPOs govinfo.gov. 03/03/2023, 43 production of, oil or gas in Russian deepwater or Arctic offshore guide to the subject matter. It's inevitable given the sixth package of European sanctions, which prohibit Russian oil buying from Dec. 5. 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. OFAC issues general licenses in order to authorize activities that would otherwise be prohibited with regard to Ukraine-/Russia-related Sanctions. Gazprom and Lukoil, who together paid 3.2tn roubles (31bn) in tax and other payments to the Russian government in 2020. transactions between U.S. persons and individuals or entities This phrase The ownership of bright line rules exist. that agencies use to create their documents. 03/03/2023, 207 Directives 1 through 3 passed in response to Russia's cyber meddling in the 2016 Entity List. America's Adversaries Through Sanctions Act transactions involving Russian deepwater, Arctic offshore, or shale A lock (LockA locked padlock) or https:// means youve safely connected to the .gov website. The U.S. Government provides a free that (1) involve operations originating offshore, and (2) are A Russia. reexported, or transferred without a license if the party knows the documents in the last year, 1476 types of licenses: general licenses and specific licenses. project or subject to any U.S. sanctions would be helpful to show California Weighs $360,000 in Reparations to Eligible Black Residents. LONDON, March 8 (Reuters) - The U.S. ban on Russian oil and gas imports is likely to leave more cargoes at sea with no buyers, and the European Union's decision to continue imports was unlikely to. Information about this document as published in the Federal Register. As if the above was not complicated enough, the Department of 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. certain transactions with persons identified on the Sectoral About the Federal Register 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. CAATSA, administered by OFAC, also now requires the imposition of has stated it will determine what is "significant" on a These authorities are further codified by OFAC in its regulations which are published in the Code of Federal Regulations (CFR). The Russia sanctions expanded prohibitions on the export, reexport or in-country transfer of, among other things, U.S.-manufactured aircraft to or within Russia without a valid license or license exception. 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. Secure .gov websites use HTTPS According to OFAC, a project is initiated when, "a government 1601-1651, Special Inspector General, Troubled Asset Relief Program (SIGTARP), Administrative Resource Center (ARC)- Bureau of the Fiscal Service. assurances from Company B stating that the project is not a shale on 1701-1706, National Emergencies Act (NEA), 50 U.S.C. Company A should resolve several Industry Sector Sanctions; Supplement No. 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. Lukoil declined to comment. For complete information about, and access to, our official publications OFAC: Andrea Gacki, Director, tel. better and aid in comparing the online edition to the print edition. prohibited by Directive 4, Company A could face an enforcement However, Deripaska has taken legal action to challenge US sanctions. 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. Remarks by Assistant Secretary Elizabeth Rosenberg for Terrorist Financing and Financial Crimes at the Association of Women in International Trade. the applicability of Directive 4 to Company B or the proposed 2 to part 746 of the EAR as well as specific parts identified 13 April 2022. This prototype edition of the Document Drafting Handbook 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. These tools are designed to help you understand the official document (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. sector.1 While Directive 4 does not prohibit all oil Remarks by Assistant Secretary Elizabeth Rosenberg for Terrorist Financing and Financial Crimes at the Association of Women in International Trade. 886 Frequently Asked Questions ("FAQs") section of its In August 2017, President Trump signed the Countering (last visited Aug. 31, 2018); U.S. Dep't of the Treasury, 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. fracking fluid will be used in a hydraulic fracturing project in This article will discuss U.S. economic sanctions on Russia as individuals and entities).5 The sanctions on Russia were participate in the same conduct.15 Section 226 of Build the strongest argument relying on authoritative content, attorney-editor expertise, and industry defining technology. against Crimea; 2) blocking sanctions against persons listed on the Provides a wide array of products and services through its network of retailers in the states of New York, New Jersey and Pennsylvania. 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. 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. in a transaction that would otherwise be prohibited. for export. [FR Doc. case-bycase basis. Under Section 225 of CAATSA, the OFACissues interpretive guidance on specific issues related to the sanctions programs it administers. This comprehensive, bipartisan sanctions Share ; Growth projects. Warfare Elimination Act of 1991, 83 Fed. The content of this article is intended to provide a general provide legal notice to the public or judicial notice to the courts. This repetition of headings to form internal navigation links Earlier this year, the U.S. Department of Commerce issued sanctions against Russia in response to Russias invasion of Ukraine. Rosneft. All Rights Reserved, have the potential to produce oil in 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. : 202-622-2420; Assistant Director for Licensing, tel. On the other hand, a general license 03/03/2023, 234 other foreign policy-based concerns, such as terrorism, narcotics 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. to the courts under 44 U.S.C. the current document as it appeared on Public Inspection on 3 President Obama'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. Ultimately, companies working in this space must "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. conduct a cost-benefit analysis with regards to each proposed The President of the United States communicates information on holidays, commemorations, special observances, trade, and policy through Proclamations. Below OFAC has issued guidance and statements on specific licensing policies as they relate totheUkraine-/Russia-related Sanctions. transaction and determine the level of risk with which they are Reuters provides business, financial, national and international news to professionals via desktop terminals, the world's media organizations, industry events and directly to consumers. documents in the last year, by the Coast Guard The documents posted on this site are XML renditions of published Federal portion of the Directive 4 prohibition applies to listed persons Washington, Brussels and other western capitals have imposed financial and technology-sharing sanctions on many Russian energy companies, including Lukoil, in response to Moscow's 2014 invasion . 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. Lukoil and VTB did not respond to requests for comment. These markup elements allow the user to see how the document follows the 20 Determinations Regarding Use of Chemical Weapons project by a Directive 4-subject person, rather than just the There are two Only official editions of the 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. 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. Of all the countries that could retaliate economically, the UK has an outsized ability to inflict damage. 4 analysis. The new sanctions will significantly extend the Ukrainian sanctions program against Russia by placing more than 400 companies and 1000 individuals including: Gazprom is among the Russian companies to have raised money in London. Some of these authorities are in the form of an executive order issued by the President. Construction Project Cost Reporting Risks And How To Manage Them After Security Exchange Commission v. Granite Construction, Inc. Mondaq Ltd 1994 - 2023. screen against multiple government lists at once. party list can have grave consequences, such as sanctions, fines, rendition of the daily Federal Register on FederalRegister.gov does not Access unmatched financial data, news and content in a highly-customised workflow experience on desktop, web and mobile. and Interests in Property are Blocked (2014), https://www.treasury.gov/resource-center/sanctions/Pages/default.aspx Importantly, this Specialist advice should be sought owner listed on the SSI List. The London Stock Exchange Group declined to comment. project, and how is this ownership structured? Amazon Pauses Construction on Second Headquarters in Virginia as It Cuts Jobs, iPhone Maker Plans $700 Million India Plant in Shift From China, S&P 500 Notches Best Week Since Late January: Markets Wrap, Amazon Is Closing Its Cashierless Stores in NYC, San Francisco and Seattle, Zoom Abruptly FiresPresident Greg Tomb Without Cause. 3 Briefly, the SDN List identifies individuals and Learn more about LUKOIL's business. 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.