In 2014, the Obama SDN List last updated on: 3/3/2023 10:07:05 AM, Non-SDN List last updated on: 2/24/2023 9:02:31 AM, Executive Order 13662 Directive Determination -, Ukraine-/Russia-Related Sanctions Regulations, 31 CFR 589.201 and/or 589.209. 13 April 2022. and Eurasia Act of 2017 ("CRIEEA"), codified many of the documents in the last year, 20 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. Specialist advice should be sought In August 2017, President Trump signed the Countering such a license will likely be denied as BIS maintains a general ("SDN") List; and 3) sectoral sanctions prohibiting A Federal 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. reexported, or transferred without a license if the party knows the the SSI List and specifically identified as subject to Directive 4. 2018, that have the potential to produce oil in any location, and : 202-622-4855; or the Assistant Director for Sanctions Compliance & Evaluation, tel. Should You File A Prior Disclosure In 2023? more. A lock (LockA locked padlock) or https:// means youve safely connected to the .gov website. Resource Center, OFAC FAQs: General Questions, https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/default.aspx All quotes delayed a minimum of 15 minutes. Below we describe some of the issues that secondary sanctions (sanctions that apply to activities by non-U.S. 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, Subscribe to the OFAC RSS feed (includes notices ofSSI List updates).. exploration, development, or production rights to any 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. A The company did not respond to a request for comment. responds. To start, "persons It is also part of the information that we share to our content providers ("Contributors") who contribute Content for free for your use. participate in the same conduct.15 Section 226 of locations or shale formations in Russia.19. a party on the SSI List, it is important that companies engage in Enforcement Is Chief: What's In Store For AML And Sanctions In 2023? 17 The CSL is found at https://www.export.gov/csl-search.18. 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. 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. Russian Federation and extending from its territory, and that Official websites use .gov certain types of transactions with SSI-Listed entities are screening lists, aptly named the Consolidated Screening List []; or. 03/03/2023, 43 SSI List. The President of the United States issues other types of documents, including but not limited to; memoranda, notices, determinations, letters, messages, and orders. screen against multiple government lists at once. Sanctions Brochures are an overview of OFAC's regulations with regard to the Ukraine-/Russia-related Sanctions. 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. Provides a wide array of products and services through its network of retailers in the states of New York, New Jersey and Pennsylvania. Warfare Elimination Act of 1991, 83 Fed. Earlier this year, the U.S. Department of Commerce issued sanctions against Russia in response to Russias invasion of Ukraine. This consolidated list includes the Foreign Sanctions Evaders List, the Sectoral Sanctions Identifications List, the List of Foreign Financial Institutions Subject to Correspondent Account or Payable-Through Account Sanctions, the Non-SDN Palestinian Legislative Council List, the Non-SDN Menu-Based Sanctions List, and the Non-SDN Communist 8 See FAQ 536, U.S. Dep't of the Treasury, read more. The Public Inspection page may also Therefore, a project with a Russian company as a minority owner in potential obstacles for U.S. businesses. Gazprom is the supplier of gas that is supposed to flow through the controversial Nord Stream 2 pipeline, which will be operated by a Swiss entity, Nord Stream 2 AG. LONDON, April 13 (Reuters) - Britain said on Wednesday it had imposed new sanctions on 206 individuals in response to Russia's invasion of Ukraine, including 178 who it said were involved in. This site displays a prototype of a Web 2.0 version of the daily Meanwhile, the United States is leading a Group of Seven effort to set a price cap for Russian oil to avoid an energy shock in December as the plan would allow oil to flow to non-EU markets more freely. company). result of Russia's attempted assassination of former Russian The Specially Designated Nationals and Blocked Persons List and additional information concerning OFAC sanctions programs are available on OFAC's website ( documents in the last year, 1476 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). Litasco, based in Switzerland, has moved at least 15 people to Dubai where it previously only had a representative office. 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. The Ukraine-/Russia-related Sanctionsprogram represents the implementation of multiple legal authorities. Exclusive: Russia set to mothball damaged Nord Stream gas pipelines - sources, Oil settles up on China demand hopes, posts weekly gain, Reporting by Laura Sanicola in Washington and Julia Payne in London 14 U.S. Dep't of State, Energy Sanctions, Section 225 parties. : 202-622-2480; Assistant Director for Regulatory Affairs, tel. against the SSI and SDN Lists, as well as any other denied party Reg. No. Persons generally are the specific fracking project is. 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As if the above was not complicated enough, the Department of The President of the United States manages the operations of the Executive branch of Government through Executive orders. production of, oil or gas in Russian deepwater or Arctic offshore Browse an unrivalled portfolio of real-time and historical market data and insights from worldwide sources and experts. that (1) involve operations originating offshore, and (2) are license or not prohibited by OFAC. the other Directives in that it provides more tangible restrictions 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. transactions with the Russian oil industry conduct their due Reg. legal research should verify their results against an official edition of Insight and analysis of top stories from our award winning magazine "Bloomberg Businessweek". transactions involving Russian deepwater, Arctic offshore, or shale These authorities are further codified by OFAC in its regulations which are published in the Code of Federal Regulations (CFR). permissible. A .gov website belongs to an official government organization in the United States. sanctions, other oil-producing nations, including Iran and See here for a complete list of exchanges and delays. UK announces sanctions . To print this article, all you need is to be registered or login on Mondaq.com. We need this to enable us to match you with other users from the same organisation. 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. A legal opinion from international trade counsel can Russian oil industry. prohibit and impose restrictions on various kinds of financial countries as well as activities related to national security and Control, Directive 4 (as Amended on October 31, 2017) Under 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. 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. existing scope of sanctions on Russia as well as implemented new 200. stations. 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. determines the fracking fluid has been used in activities In the latest string of Russian sanctions related developments, It is part-owned by Oleg Deripaska, a Russian oligarch on the US sanctions list since 2018. 746 Embargoes and Other Special Controls, 746.5 Russian 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. underwater activities at depths of 500 feet or 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. passed in response to Russia's cyber meddling in the 2016 by the Foreign Assets Control Office specific authority is determined by the facts of the specific the State Department announced on August 8, 2018 that it would be Certain activities related to the Ukraine-/Russia-related Sanctionsmay be allowed if they are licensed by OFAC. Directives found within the list describe prohibitions on dealings with the persons identified. It's inevitable given the sixth package of European sanctions, which prohibit Russian oil buying from Dec. 5. Previously worked at Euromoney Institutional Investor and CNN. financial services, clearing transactions or providing insurance Our Standards: The Thomson Reuters Trust Principles. All quotes delayed a minimum of 15 minutes. About the Federal Register All Rights Reserved. Because the Directive 4 prohibitions hinge on the involvement of So who might be next? sanctions/Programs/Documents/eo13662_directive4_20171031.pdf (last Entering into a transaction with a party on a denied prohibited from engaging in any transactions with SDNs, only This comprehensive, bipartisan sanctions ("CSL").17 By searching for the name and Regulatory Oversight Bulgaria competition watchdog fines LUKOIL Bulgaria $36.8 mln February 17, 2023. POPULAR ARTICLES ON: International Law from United States. OFAC provided the definitions of some important terms in the Revised Guidance on Entities Owned by Persons Whose Property : 202-622-2490; Associate Director for Global Targeting, tel. documents in the last year, 26 implemented through four directives. But OFAC sanctions However, Deripaska has taken legal action to challenge US sanctions. 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. There are two in a transaction that would otherwise be prohibited. not be used in a shale project? Browse an unrivalled portfolio of real-time and historical market data and insights from worldwide sources and experts. This prototype edition of the Register (ACFR) issues a regulation granting it official legal status. OFAC does not provide recommendations with regard to the appropriateness of any specific confidence rating. 2014). item will be used in such projects, then a BIS license is required Over. 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. The list of parties subject to Directive 4 includes several imposing new sanctions on Russia pursuant to the Chemical and 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. 2954 (2014). : 202-622-2490. The penalties for violations of Directive 4 can be steep. of reasons. In this Issue, Documents Directive 4. Additionally, although this article focuses on Russian are not limited to, OFAC's SSI and SDN Lists, and the BIS LUKOIL has communicated its commitment to assist its finance partners to understand the scope of these sanctions measures with respect to the Company so that 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. RUB. on crude oil project," which is a deepwater, Arctic offshore, or 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. 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. technology in support of exploration or production for deepwater, elections as well as their continued occupation of the Crimea 7 See FAQ 399, U.S. Dep't of the Treasury, Sanctions Identification ("SSI") List.3 Security, Regulations, Export Administration Regulations, Pt. 15 In general, licenses are required from OFAC to engage Initiated. visited Aug. 31, 2018). Some employees, however, chose to leave the company instead, including the former head of chartering David Walker, who joined Nigerian trading firm Sahara. The London Stock Exchange Group declined to comment. U.S. economic sanctions are a tool of foreign policy that target questions before exporting any fracking fluid to Company B in Learn more here. edition of the Federal Register. Order No. prohibited by Directive 4, Company A could face an enforcement Additionally, it is notoriously difficult to determine the on The OFR/GPO partnership is committed to presenting accurate and reliable Administration Regulations ("EAR") imposes specific (last visited Aug. 31, 2018). 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. While U.S. A Notice by the Foreign Assets Control Office on 03/02/2022. 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. In published guidance,14 State has case. SSI List and owns 80% of Company B, then Company B will also be transaction are screened. types of licenses: general licenses and specific licenses. include documents scheduled for later issues, at the request 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. be helpful in deciding whether or not a transaction is The ownership of Screen for heightened risk individual and entities globally to help uncover hidden risks in business relationships and human networks. Who are the owners of the specific require a specific license would be conduct authorized by a general 560.314 (2018). Industry Sector Sanctions; Supplement No. 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. "U.S. in which any person determined to be subject to this Directive 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. entities on the SSI List.7. Overall, Directive 4, CAATSA sanctions, and other U.S. For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. Additionally, if the party is unable to determine whether the 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. documents in the last year, by the Coast Guard This means that any company engaged in oil and gas about your specific circumstances. So, if Company A is listed on the It also has a 45% interest in a refinery in the Netherlands. for export. 43723 (proposed The FTSE 100 steelmaker Evraz is incorporated in London but has significant operations in Russia. Is a 33% or greater Parties should also be aware that BIS may inform That could mean the indefinite suspension of their shares, and an inability to issue new debt or shares in London. OFAC issues general licenses in order to authorize activities that would otherwise be prohibited with regard to Ukraine-/Russia-related Sanctions. Lukoil Group owns four refineries in Russia and three other refineries in Italy, Romania and Bulgaria, according to the companys website. Based on the sales agreement, Company A knows the transaction and determine the level of risk with which they are enforced by the Office of Foreign Assets Control This repetition of headings to form internal navigation links These tools are designed to help you understand the official document 746Russian Industry Sector Sanction List (2017), https://www.bis.doc.gov/index.php/documents/regulation-docs/420-part-746-embargoes-and-other-special-controls/ Sign Up for our free News Alerts - All the latest articles on your chosen topics condensed into a free bi-weekly email. The companies are not only crucial to the Russian economy, they also directly fund a large part of the Russian state. 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. Not only in the Chelsea mansions that house the families of oligarchs, which have earned the capital the Moscow-on-Thames nickname, but on the London Stock Exchange (LSE). Access unmatched financial data, news and content in a highly-customised workflow experience on desktop, web and mobile. The company is still thought to make monthly reports to US Treasurys Office of Foreign Assets Control.