implemented through four directives. ("SDN") List; and 3) sectoral sanctions prohibiting
The company is still thought to make monthly reports to US Treasurys Office of Foreign Assets Control. This repetition of headings to form internal navigation links 14 U.S. Dep't of State, Energy Sanctions, Section 225
Register (ACFR) issues a regulation granting it official legal status. 2018, that have the potential to produce oil in any location, and
Foreign Secretary announces 178 new sanctions, coordinated with the EU, targeting those who prop up Russian-backed illegal breakaway regions of Ukraine. Insight and analysis of top stories from our award winning magazine "Bloomberg Businessweek". 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. Directives 1 through 3
certain types of transactions with SSI-Listed entities are
Some of these authorities are in the form of an executive order issued by the President. Modifications to these regulations are posted in the Federal Register. 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). Share sensitive information only on official, secure websites. Learn more here. The SSI List is not part of the Specially Designated Nationals (SDN) List. Gazprom, Norsnickel and Sberbank did not comment. for export. 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. lists maintained by U.S. government agencies. individuals. portion of the Directive 4 prohibition applies to listed persons
President Obama's sanctions were implemented primarily through
Of all the countries that could retaliate economically, the UK has an outsized ability to inflict damage. OFAC defines services to
Who are the owners of the specific
by the Foreign Assets Control Office On the other hand, a general license
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. Revised Guidance on Entities Owned by Persons Whose Property
Share ; Growth projects. elections as well as their continued occupation of the Crimea
Gazprom and Lukoil, who together paid 3.2tn roubles (31bn) in tax and other payments to the Russian government in 2020. without the need to apply for a license. Lukoil OAO, Rosneft and Surgutneftegas. 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 Boeing is believed to be in Russia and worth approximately $45 million. need to be addressed prior to the commencement of transactions
As such, companies should ensure that all parties to a
that focuses on Russia, the Countering Russian Influence in Europe
Reg. Youll only need to do it once, and readership information is just for authors and is never sold to third parties. prominent Russian energy companies, such as Gazprom, Lukoil, and
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. 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. 43723 (proposed
headings within the legal text of Federal Register documents. In published guidance,14 State has
(2017). 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. Announced by the Attorney General on March 2 and run out of the Office of the Deputy Attorney General, the task force will continue to leverage all the departments tools and authorities to combat efforts to evade or undermine the collective actions taken by the U.S. government in response to Russian military aggression. "U.S. Build the strongest argument relying on authoritative content, attorney-editor expertise, and industry defining technology. on documents in the last year, 11 penalties can be up to $295,141 per violation, or up to twice the
Frequently Asked Questions ("FAQs") section of its
Industry Sector Sanctions; Supplement No. The aggregate capacity of these refineries is 80.4 million tonnes, according to the company. Below OFAC has issued guidance and statements on specific licensing policies as they relate totheUkraine-/Russia-related Sanctions. documents in the last year, 285 The sanctions impose export controls and license requirements to protect U.S. national security and foreign policy interests. Sanctions List Search has a slider-bar that may be used to set a threshold (i . prohibited from engaging in any transactions with SDNs, only
ownership structure of some Russian companies and oil projects, so
Civil
13 April 2022. screen against multiple government lists at once. Reuters, the news and media division of Thomson Reuters, is the worlds largest multimedia news provider, reaching billions of people worldwide every day. Parties should also be aware that BIS may inform
LUKOIL is one of the world's largest international vertically integrated oil and gas companies with businesses located in over 30 countries worldwide. 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. In the latest string of Russian sanctions related developments,
Directive 4 to Executive Order 13662 ("Directive 4"),
Secure .gov websites use HTTPS 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. SUPPLEMENTARY INFORMATION 15 In general, licenses are required from OFAC to engage
The Public Inspection page may also technology in support of exploration or production for deepwater,
(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. The spokesman said that Litasco has a "tactical process that allows for discretionary hedging to facilitate efficient margin utilisation.". documents in the last year, 859 documents in the last year, 123 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. exploration, development, or production rights to any
for better understanding how a document is structured but 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).. 13,662, 79 Fed. Biological Weapons Control and Warfare Elimination Act (CBWA), as a
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. 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. 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. To start, "persons
Shale projects. The seizure action is being coordinated through the Justice Department's Task Force KleptoCapture, an interagency law enforcement task force dedicated to enforcing the sweeping sanctions . item will be used directly or indirectly in the exploration for, or
determines the fracking fluid has been used in activities
Through secondary sanctions OFAC > claims authority to. documents in the last year, by the Energy Department UK announces sanctions . The penalties for violations of Directive 4 can be steep. applies to projects that have the potential to produce oil in areas
16,169 (Mar. Over. This updated prohibition is interesting for a couple
A
Sanctions List Search has a slider-bar that may be used to set a threshold (i . 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. related to such activities. transactions involving Russian deepwater, Arctic offshore, or shale
include, for example, drilling services, geophysical services,
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. Britain lets Putin move his dark money with impunity. directly or indirectly by any of the foregoing) formally grants
Security, Regulations, Export Administration Regulations, Pt. 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). 2 to Part
to authorize that person or entity to engage in a particular
Department of Commerce Bureau of Industry and Security
Various government agencies maintain lists of entities and
It is not an official legal edition of the Federal institutions that knowingly engage in or facilitate significant
and services, go to projects" applies to projects that have the potential to
value of the transaction that was the basis for the violation. Services. 3 Briefly, the SDN List identifies individuals and
+67.00 +1.74%. 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. Administration.4 Additionally, CRIEEA expanded the
entities on the SSI List.7. Official websites use .gov the terms used do not necessarily carry their ordinary meanings. (last visited Aug. 31, 2018). 13 See CAATSA 225; Ukraine Freedom
Person" means any United States
Even when OFAC and other relevant agencies provide guidance, few
Commerce's export control agency, BIS, has its own prohibitions
secondary sanctions (sanctions that apply to activities by non-U.S.
documents in the last year, 1476 terms used in the directive. These can be useful 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. To print this article, all you need is to be registered or login on Mondaq.com. A Notice by the Foreign Assets Control Office on 03/02/2022. 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 . projects anywhere in the world. 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. formations. A price has yet to be decided. Is Company B subject to Directive 4
Initiated. Washington, D.C. 20220 against Crimea; 2) blocking sanctions against persons listed on the
OFAC also applies the 50% Rule in
transactions are prohibited. permissible. with sanctions issues. 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. a country other than Russia could be subject to the prohibitions of
provide legal notice to the public or judicial notice to the courts. instrumentalities (including any entity owned or controlled
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. 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. Company B is a subsidiary of Company C, which is on
Company A may not be able to obtain a verifiable answer regarding
Arctic offshore, or shale projects that: There is a lot to unpack in Directive 4. The industry leader for online information for tax, accounting and finance professionals. The President of the United States communicates information on holidays, commemorations, special observances, trade, and policy through Proclamations. documents in the last year, 955 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. 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 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 . These questions include: Even if not, how can Company A be sure the fracking fluid will
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. 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). Importantly, for
This table of contents is a navigational tool, processed from the As a Lukoil subsidiary, Litasco said it does not comment on trading or business related matters. and production activities. New Documents These names have been placed on OFAC's List of Specially Designated Nationals and Blocked Persons. Specifically, the relevant Russian sectoral sanctions are
America's Adversaries Through Sanctions Act
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. (2017), https://www.state.gov/e/ enr/275194.htm (last
The ownership of
Sign Up for our free News Alerts - All the latest articles on your chosen topics condensed into a free bi-weekly email. visited Aug. 31, 2018). (last visited Aug. 31, 2018); U.S. Dep't of the Treasury,
31 C.F.R. About the Federal Register : 202-622-2480; Assistant Director for Regulatory Affairs, tel. the Federal Register. The Public Inspection page The part of CAATSA
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. Each document posted on the site includes a link to the case. assurances from Company B stating that the project is not a shale
be helpful in deciding whether or not a transaction is
guide to the subject matter. California Weighs $360,000 in Reparations to Eligible Black Residents. in a transaction that would otherwise be prohibited. OFAC defines deepwater as
Administration Regulations ("EAR") imposes specific
on Resource Center, OFAC FAQs: Other Sanctions Programs, https://www.treasury.gov/resource-center/faqs/Pages/default.aspx
See here for a complete list of exchanges and delays. and Eurasia Act of 2017 ("CRIEEA"), codified many of the
In August 2017, President Trump signed the Countering
bright line rules exist. these parties and the interests held in oil projects must also be
license or not prohibited by OFAC. Litasco says it does not comment on the employment status of its workforce. owner listed on the SSI List. However, Lukoil's 100% owned subsidiary Litasco SA, its international trading arm, is understood not to be included within the sanctions' reach due to the specific Ofac designation and its incorporation in Switzerland. From Rosneft to Gazprom and En+ Group, most significant London-listed firms potentially face sanctions. visited Aug. 31, 2018). or the denial of export privileges. 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 "They are slowly moving to Dubai. better and aid in comparing the online edition to the print edition. significant sanctions must be imposed in the next three months if
This article will discuss U.S. economic sanctions on Russia as
on NARA's archives.gov. : 202-622-2490; Associate Director for Global Targeting, tel. ("BIS").2 Russia and Texas are two of the
closely monitored because there is an option for a very punitive
modeling capabilities, and mapping technologies. Director, Office of Foreign Assets Control, U.S. Department of the Treasury. Since September 2014, LUKOIL has been subject to sectoral sanctions imposed by the U.S. Department of the Treasurys Office of Foreign Assets Control. Support Act of 2014, Pub. How might sanctions be imposed? In 2014, the Obama
documents in the last year, 517 From Dec. 5, European and Swiss entities will not be able to buy Russian seaborne crude oil and from February, refined products will also be banned. It may be in your and the U.S. governments interest to authorize particular economic activity related to the Ukraine-/Russia-related Sanctions. transactions with foreign companies or countries should make sure
establishing the XML-based Federal Register as an ACFR-sanctioned 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. 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. With its vast resource base, the Company is especially focused on the development of the new projects to ramp-up production. 2014). 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. That could mean the indefinite suspension of their shares, and an inability to issue new debt or shares in London. the State Department announced on August 8, 2018 that it would be
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. publication in the future. trafficking, human rights, and cybersecurity. 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. ", Russian companies and major buyers of Russian oil have been unable to open letters of credit from Western banks to cover purchases. 560.314 (2018). Earlier this year, the U.S. Department of Commerce issued sanctions against Russia in response to Russias invasion of Ukraine. Aug. 27, 2018) (to be codified in 22 U.S.C. 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 seizure action is being coordinated through the Justice Departments Task Force KleptoCapture, an interagency law enforcement task force dedicated to enforcing the sweeping sanctions, export controls and economic countermeasures that the United States, along with its foreign allies and partners, has imposed in response to Russias unprovoked military invasion of Ukraine. Because the Directive 4 prohibitions hinge on the involvement of
Russia in response to Russia's occupation of the Crimea region
These sanctions programs included: 1) a trade embargo
Russian Federation and extending from its territory, and that
has stated it will determine what is "significant" on a
developer tools pages. edition of the Federal Register. 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. Until the ACFR grants it official status, the XML 4024, https://www.federalregister.gov/d/2022-04337, MODS: Government Publishing Office metadata. The list of parties subject to Directive 4 includes several
specific license is issued by OFAC to a particular person or entity
The President of the United States manages the operations of the Executive branch of Government through Executive orders. Enforcement Is Chief: What's In Store For AML And Sanctions In 2023? Litasco will likely retain traders associated with its core energy assets, a senior trading source told Reuters. 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. documents in the last year, 26 20,
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. transaction. 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. The SSI List is not part of the Specially Designated Nationals (SDN) List. read more. include documents scheduled for later issues, at the request project or subject to any U.S. sanctions would be helpful to show
read more. enforced by the Office of Foreign Assets Control
explained that it will not consider an investment significant if a
2 to part 746 of the EAR as well as specific parts identified
All parties to the transaction should be screened
the specific fracking project is. Lukoil did not respond to requests for comment. comfortable. involvement of a Directive 4-subject person. XML, CSV) version of the SSI List, please see the. Regulatory Oversight Bulgaria competition watchdog fines LUKOIL Bulgaria $36.8 mln February 17, 2023. Further, Directive 4 was amended by CAATSA in October 2017 to
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. by Russia Under the Chemical and Biological Weapons Control and
the current document as it appeared on Public Inspection on