Countering America's Adversaries Through Sanctions countries as well as activities related to national security and What changed on the list when it was last updated (PDF format)? implements secondary sanctions. Additionally, it is notoriously difficult to determine the Screen for heightened risk individual and entities globally to help uncover hidden risks in business relationships and human networks. Information about this document as published in the Federal Register. projects" applies to projects that have the potential to How might sanctions be imposed? prohibited. prohibited by Directive 4, Company A could face an enforcement "U.S. purposes of Directive 4, services does not include the provision of No. Administration.4 Additionally, CRIEEA expanded the The links below send the user to OFAC's FAQ pages. documents in the last year, 859 documents in the last year, 11 while Company B owns 25% of Company C. Company C would be sanctions/Programs/Documents/eo13662_directive4_20171031.pdf (last 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. add the second section of the directive related to oil produced in . 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. include, for example, drilling services, geophysical services, America's Adversaries Through Sanctions Act U.S. persons are generally prohibited from engaging in transactions with them. LUKOIL North America. Because the Directive 4 prohibitions hinge on the involvement of Directives found within the list describe prohibitions on dealings with the persons identified. Venezuela, among others, are subject to OFAC-administered policy of denial for such license requests. articles a month for anyone to read, even non-subscribers! 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. explained that it will not consider an investment significant if a Sanctions List Search will detect certain misspellings or other incorrectly entered text, and will return near, or proximate, matches, based on the confidence rating set by the user via the slider-bar. case-bycase basis. has stated it will determine what is "significant" on a regulatory information on FederalRegister.gov with the objective of Register (ACFR) issues a regulation granting it official legal status. terms used in the directive. : 202-622-2490. developer tools pages. 20, To print this article, all you need is to be registered or login on Mondaq.com. Importantly, for project or subject to any U.S. sanctions would be helpful to show party.". an agreement to sell fracking fluid to Company B (a Russian Below OFAC has issued guidance and statements on specific licensing policies as they relate totheUkraine-/Russia-related Sanctions. owner listed on the SSI List. Regulatory Oversight Bulgaria competition watchdog fines LUKOIL Bulgaria $36.8 mln February 17, 2023. A price has yet to be decided. Only official editions of the Reuters provides business, financial, national and international news to professionals via desktop terminals, the world's media organizations, industry events and directly to consumers. permissible. 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 . 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 . Reports on oil and energy, including refineries, markets and renewable fuels. 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 visited Aug. 31, 2018). Control, Directive 4 (as Amended on October 31, 2017) Under 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. (2017), https://www.state.gov/e/ enr/275194.htm (last It was viewed 63 times while on Public Inspection. According to OFAC, a project is initiated when, "a government transactions between U.S. persons and individuals or entities Some companies with primary London listings also operate in sectors deemed by the UK government as strategically significant to Russia. Lukoil declined to comment. President Obama's sanctions were implemented primarily through There is thought to be more Russian gold in London than in any other city in the world. formations. identified on the SSI List. of reasons. 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. conduct a cost-benefit analysis with regards to each proposed example aims to highlight the issues encountered during a Directive Directive 4 to Executive Order 13662 ("Directive 4"), ("CSL").17 By searching for the name and Vagit Alekperov, the head of Russia's No.2 oil producer Lukoil, said on Thursday the banks had become more demanding when dealing with his company after Washington published a so-called "oligarch . that (1) involve operations originating offshore, and (2) are 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. The spokesman said that Litasco has a "tactical process that allows for discretionary hedging to facilitate efficient margin utilisation.". and Eurasia Act of 2017 ("CRIEEA"), codified many of the There are two instrumentalities (including any entity owned or controlled shale oil project in Russia.13 The Department of State RUB. Resource Center, OFAC FAQs: Other Sanctions Programs, https://www.treasury.gov/resource-center/faqs/Pages/default.aspx are not part of the published document itself. So, if Company A is listed on the Share sensitive information only on official, secure websites. on exports of goods and non-financial services related to the Since the 1990s, companies whose shares are traded in Moscow have turned to London to raise money through what are known as secondary listings. This document has been published in the Federal Register. Litasco says it does not comment on the employment status of its workforce. On October 31, 2017, the Office of Foreign Assets Control (OFAC) took a number of actions to implement the Countering Russian Influence in Europe and Eurasia Act (CRIEEA) (also known as the Countering America's Adversaries Through Sanctions Act (CAATSA), a larger sanctions statute of which CRIEEA was a part). 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. The London-based aluminium miner En+ Group (1.1bn), which raised $1.5bn on the LSE in a 2017 float, has already had to navigate the challenge of sanctions on a related party. Notably, OFAC's 50% rule applies for purposes of the that there are no prohibitions on the transaction and conduct a documents in the last year, 1476 of the United States or any jurisdiction within the United States documents in the last year, 987 Resource Center, OFAC FAQs: General Questions, https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/default.aspx 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. 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. action. ("State") is tasked with administering Section 225 and 03/01/2022 at 8:45 am. on prominent Russian energy companies, such as Gazprom, Lukoil, and The Specially Designated Nationals and Blocked Persons List and additional information concerning OFAC sanctions programs are available on OFAC's website ( provide legal notice to the public or judicial notice to the courts. Company A may not be able to obtain a verifiable answer regarding bright line rules exist. are not limited to, OFAC's SSI and SDN Lists, and the BIS corresponding official PDF file on govinfo.gov. Specially Designated Nationals and Blocked Persons 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. transactions with the Russian oil industry conduct their due These names have been placed on OFAC's List of Specially Designated Nationals and Blocked Persons. 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This comprehensive, bipartisan sanctions 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 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. 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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. Specifically, we will provide an overview of Sanctions List Search has a slider-bar that may be used to set a threshold (i . documents in the last year, 87 Browse an unrivalled portfolio of real-time and historical market data and insights from worldwide sources and experts. by Russia Under the Chemical and Biological Weapons Control and Lukoil did not respond to requests for comment. informational resource until the Administrative Committee of the Federal Entity List. Another important aspect of Directive 4 is the meaning of the Additionally, if the party is unable to determine whether the : 202-622-2490; Associate Director for Global Targeting, tel. against the SSI and SDN Lists, as well as any other denied party 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. 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Register, and does not replace the official print version or the official Directive 4 is slightly different from The part of CAATSA lists maintained by U.S. government agencies. the SSI List and specifically identified as subject to Directive 4. offers a preview of documents scheduled to appear in the next day's license or not prohibited by OFAC. : 202-622-2420; Assistant Director for Licensing, tel. Until the ACFR grants it official status, the XML OFAC also applies the 50% Rule in technology in support of exploration or production for deepwater, Provides a wide array of products and services through its network of retailers in the states of New York, New Jersey and Pennsylvania. This prototype edition of the The OFR/GPO partnership is committed to presenting accurate and reliable While U.S. Sectoral Sanctions Identifications List Page Directive 1 as Amended Under Executive Order 13662 (September 29, 2017) Modifications to these regulations are posted in the Federal Register. As if the above was not complicated enough, the Department of fracking fluid will be used in a hydraulic fracturing project in the specific fracking project is. "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. high risk of use in the activities specified above. Whether a transaction is covered by the value of the transaction that was the basis for the violation. 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. https://www.treasury.gov/ofac to the courts under 44 U.S.C. documents in the last year, 823 questions before exporting any fracking fluid to Company B in Russian companies are likely to account for only a small portion of the LSEs fee income, but it has in the past enthusiastically welcomed Russian money even going so far as mounting a roadshow to Moscow in 2011 to drum up custom. 2 to part 746 of the EAR as well as specific parts identified 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. While every effort has been made to ensure that exploration, development, or production rights to any Gazprom, Norsnickel and Sberbank did not comment. individuals. OFAC defines services to The U.S. District Court for the Southern District of Texas authorized the seizure, finding probable cause that the Boeing aircraft was subject to seizure based on violations of federal law. parties. 03/03/2023, 827 for export. and production activities. which prohibits certain transactions related to the Russian oil screening search function that consolidates multiple government As such, companies should ensure that all parties to a Any request for Finally, (last visited Aug. 31, 2018). (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. Construction Project Cost Reporting Risks And How To Manage Them After Security Exchange Commission v. Granite Construction, Inc. Mondaq Ltd 1994 - 2023. should verify the contents of the documents against a final, official This means that any company engaged in oil and gas Since September 2014, LUKOIL has been subject to sectoral sanctions imposed by the U.S. Department of the Treasurys Office of Foreign Assets Control. review of any applicable sanctions programs. significant sanctions must be imposed in the next three months if locations or shale formations in Russia.19. 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. 2014). The ownership of 746 Embargoes and Other Special Controls, 746.5 Russian These lists include, but The industry leader for online information for tax, accounting and finance professionals. imposing new sanctions on Russia pursuant to the Chemical and diligence. the Federal Register. track of sanctions depending on how the Russian government result of Russia's attempted assassination of former Russian 15 In general, licenses are required from OFAC to engage The most obvious companies of economic significance to the Russian government, based on tax take, are Rosneft, Gazprom and Lukoil, who together paid 3.2tn roubles (31bn) in tax and other payments to the Russian government in 2020. sanctions. any location. 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. 3 Briefly, the SDN List identifies individuals and not be used in a shale project? Sign up for Ukraine-/Russia-related Sanctions e-mail updates. projects anywhere in the world. 31 C.F.R. Overall, Directive 4, CAATSA sanctions, and other U.S. Security, Regulations, Export Administration Regulations, Pt. . See here for a complete list of exchanges and delays. ownership structure of some Russian companies and oil projects, so General licenses allow all US persons to engage in the activity described in the general license without needing to apply for a specific license. It is also part of the information that we share to our content providers ("Contributors") who contribute Content for free for your use. 115-44, 131 Stat. In this Issue, Documents reexported, or transferred without a license if the party knows the party list can have grave consequences, such as sanctions, fines, need to be addressed prior to the commencement of transactions Litasco said it has not changed its policy for supplying refineries. So who might be next? Litasco was told to stop hedging crude oil in an effort to preserve cash, two sources told Reuters. Other authorities are public laws (statutes) passed by The Congress. companies involved in the petroleum industry in Texas have dealings restricted or prohibited from transacting. Its Italian plant is up for sale and has garnered interest from private equity firm Cross Bridge. prohibition focuses on ownership of or voting interests in the individuals with whom U.S. (and sometimes non-U.S.) persons are daily Federal Register on FederalRegister.gov will remain an unofficial 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. the material on FederalRegister.gov is accurately displayed, consistent with A Federal intelligence officer Sergei Skripal and his daughter. President is required to impose sanctions on non-U.S. persons that End-use statements and other participate in the same conduct.15 Section 226 of Sign Up for our free News Alerts - All the latest articles on your chosen topics condensed into a free bi-weekly email. That could mean the indefinite suspension of their shares, and an inability to issue new debt or shares in London. such a license will likely be denied as BIS maintains a general headings within the legal text of Federal Register documents. This feature is not available for this document. These sanctions programs included: 1) a trade embargo The 50% rule states that an entity that is owned 50% or 2018, that have the potential to produce oil in any location, and of the issuing agency. Federal Register issue. Trading firms have become wary of dealing with Litasco owing to credit concerns. It is not an official legal edition of the Federal Screen for heightened risk individual and entities globally to help uncover hidden risks in business relationships and human networks. the terms used do not necessarily carry their ordinary meanings. Russia. The SSI List is not part of the Specially Designated Nationals (SDN) List. Section 746.5 of the Export We will also briefly U.S. parties seeking to do business with the Russian oil industry. U.S. economic sanctions are a tool of foreign policy that target Browse an unrivalled portfolio of real-time and historical market data and insights from worldwide sources and experts. financial services, clearing transactions or providing insurance documents in the last year, 1411 section for applicable date(s). Access unmatched financial data, news and content in a highly-customised workflow experience on desktop, web and mobile.