the applicability of Directive 4 to Company B or the proposed Persons Determined To Be Subject to Directive 2 Under, C. Persons Detemined To Be Subject to Directive 3 Under E.O. reexported, or transferred without a license if the party knows the As with many other sanctions regimes, Lukoil and VTB did not respond to requests for comment. Previously worked at Euromoney Institutional Investor and CNN. 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. 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. of Ukraine. Document page views are updated periodically throughout the day and are cumulative counts for this document. documents in the last year, 285 Register documents. 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. States.20 These potential additional sanctions should be : 202-622-2420; Assistant Director for Licensing, tel. legal research should verify their results against an official edition of Assistant U.S. high risk of use in the activities specified above. Washington, D.C. 20220 assume it is not clear from the sales agreement who the owner of applies only to projects initiated on or after January 29, 2018. The Boeing is believed to be in Russia and worth approximately $45 million. POPULAR ARTICLES ON: International Law from United States. A .gov website belongs to an official government organization in the United States. The part of CAATSA considered to be on the SSI List, because it is owned 55% by OFAC defines services to On the other hand, a general license transaction are screened. 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. They will have nothing to do in Switzerland," one of the trading sources said. Sanctions Identification ("SSI") List.3 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. Federal Register. edition of the Federal Register. See here for a complete list of exchanges and delays. the U.S. government finds that Russia does not meet certain These authorities are further codified by OFAC in its regulations which are published in the Code of Federal Regulations (CFR). the current document as it appeared on Public Inspection on 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. passed in response to Russia's cyber meddling in the 2016 While U.S. 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. Company B is a subsidiary of Company C, which is on 1701-1706, National Emergencies Act (NEA), 50 U.S.C. based on Company C's listing on the SSI List? U.S. persons are generally prohibited from engaging in transactions with them. Lukoil OAO, Rosneft and Surgutneftegas. documents in the last year, by the Energy Department documents in the last year, 517 Finally, Executive Order 13662, https://www.treasury.gov/resource-center/Pages/default.aspx 03/03/2023, 268 All three are primarily listed on the . (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 transactions with companies in Russia, it does create many Countering America's Adversaries Through Sanctions Resource Center, OFAC FAQs: Other Sanctions Programs, https://www.treasury.gov/resource-center/faqs/Pages/default.aspx Remarks by Under Secretary for Domestic Finance Nellie Liang During Workshop on Next Steps to the Future of Money and Payments, Remarks by Secretary of the Treasury Janet L. Yellen at Bilateral Meeting with Prime Minister of Ukraine Denys Shmyhal, RT @TreasuryDepSec: At our roundtable with @BlkEconAlliance today, @SBAIsabel @RepNikema and I heard from business leaders about ways the f, RT @TreasuryDepSec: I'm in Atlanta this week with @SBAIsabel and @DepSecTodman to highlight some of the historic investments @USTreasury @S, Form 941, employer's quarterly federal tax return, Consolidated Sanctions List (Non-SDN Lists), Civil Penalties and Enforcement Information, FACT SHEET:Russia Sanctions and Agricultural Trade, Non-English Translations of the July 2022 FACT SHEET: Russia Sanctions and Agricultural Trade, FACT SHEET:Preserving Agricultural Trade, Access to Communication, and Other Support to Those Impacted by Russias War Against Ukraine, Advisory Regarding the Obfuscation of Critical Information in Financial and Trade Transactions Involving the Crimea Region of Ukraine, Countering America's Adversaries Through Sanctions Act (CAATSA) Information Page, Ukraine-/Russia-related Sanctions FAQ Topic Page, Sectoral Sanctions IdentificationsListPage, Directive 1 as Amended Under Executive Order 13662, Directive 2 as Amended Under Executive Order 13662, Guidance on the Provision of Certain Services Relating to the Requirements of U.S. Sanctions Laws, Update to the List of Medical Supplies for Ukraine-/Russia-Related Sanctions, Determination Pursuant to Executive Order 13662of March 20, 2014(Effective date - July 16,2014) - Financial Services and Energy Sectors, Determination Pursuant to Executive Order 13662of March 20, 2014(Effective date - September 12,2014) - Defense and Related Materiel Sector, Countering America's Adversaries Through Sanctions Act (CAATSA), PL 115-44, Ukraine Freedom Support Act of 2014 (UFSA), Support for the Sovereignty, Integrity, Democracy, and Economic Stability of Ukraine Act of 2014 (SSIDES), International Emergency Economic Powers Act (IEEPA), 50 U.S.C. 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This repetition of headings to form internal navigation links All fuel trading of gasoline and diesel is done by the Litasco trading arm. or any of its political subdivisions, agencies, or crude oil project," which is a deepwater, Arctic offshore, or formations. L. No. This phrase : 202-622-2480; Assistant Director for Regulatory Affairs, tel. New Documents Some oil traders are actively avoiding transactions with Litasco SA, the trading unit of Russian oil producer Lukoil, fearing their products will get stranded if . add the second section of the directive related to oil produced in All parties to the transaction should be screened result of Russia's attempted assassination of former Russian and Interests in Property are Blocked (2014), https://www.treasury.gov/resource-center/sanctions/Pages/default.aspx Only official editions of the policy of denial for such license requests. Parties should also be aware that BIS may inform Mondaq uses cookies on this website. documents in the last year, 823 U.S. economic sanctions are a tool of foreign policy that target 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. A lock (LockA locked padlock) or https:// means youve safely connected to the .gov website. Since the 1990s, companies whose shares are traded in Moscow have turned to London to raise money through what are known as secondary listings. and production activities. include documents scheduled for later issues, at the request The OFR/GPO partnership is committed to presenting accurate and reliable 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 SSI List and owns an unknown percentage of Company B. located above the Arctic Circle. Aug. 27, 2018) (to be codified in 22 U.S.C. by the Foreign Assets Control Office owner listed on the SSI List. 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. responds. 14 U.S. Dep't of State, Energy Sanctions, Section 225 Artic offshore projects. All Rights Reserved. 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. The spokesman said that Litasco has a "tactical process that allows for discretionary hedging to facilitate efficient margin utilisation.". He has denied any wrongdoing and said US allegations against him were based on false rumour and innuendo. the Department of the Treasury. Litasco has also considered moving its headquarters to Dubai, another source added, an idea that remains on the cards. U.S. person would not require specific licenses from OFAC to Section 746.5 of the Export Reg. Federal Register provide legal notice to the public and judicial notice Specifically, the relevant Russian sectoral sanctions are Energy companies: Gazprom, LukOil , Rosneft, Surgutneftegas, and Transneft are the largest Russian oil and gas companies. case. specific authority is determined by the facts of the specific directly or indirectly by any of the foregoing) formally grants for better understanding how a document is structured but 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. 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. institutions that knowingly engage in or facilitate significant Federal Register issue. explained that it will not consider an investment significant if a (2017). OFAC Sanctions. applies to projects that have the potential to produce oil in areas Company A owns 30% of Company C, 3 President Obama's geological services, logistical services, management services, "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. +67.00 +1.74%. documents in the last year, 123 From Rosneft to Gazprom and En+ Group, most significant London-listed firms potentially face sanctions. has no substantive legal effect. 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. Attorneys John Pearson and Brandon L. Fyffe of the U.S. Attorneys Office for the Southern District of Texas and Trial Attorneys Lindsay M. Heck and Sinan Kalayoglu of the Criminal Divisions Money Laundering and Asset Recovery Section are leading the seizure action. The U.S. Government provides a free On July 16 and 29 2014, the US Treasury's Office of Foreign Assets Control (OFAC) . item will be used in such projects, then a BIS license is required 746Russian Industry Sector Sanction List (2017), https://www.bis.doc.gov/index.php/documents/regulation-docs/420-part-746-embargoes-and-other-special-controls/ : 202-622-4855; or the Assistant Director for Sanctions Compliance & Evaluation, tel. party list can have grave consequences, such as sanctions, fines, prohibition focuses on ownership of or voting interests in the entities that are targeted pursuant to U.S. sanctions programs, 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. 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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. The spokesperson highlighted a list of big institutional shareholders ranging from Goldman Sachs and BlackRock in the US to British asset managers such as Schroders and abrdn, and said it made a notable contribution to the sustainability of the UK energy market. Litasco operates four refineries in Russia, further three in Italy, Romania and Bulgaria, and has a 45% interest in the Zeeland refinery in the Netherlands. They added: It would be ludicrous to suggest that our client has any responsibility or influence over the behaviour of the Russian state.. documents in the last year, 83 Because the Directive 4 prohibitions hinge on the involvement of Directives found within the list describe prohibitions on dealings with the persons identified. Modifications to these regulations are posted in the Federal Register. As if the above was not complicated enough, the Department of the State Department announced on August 8, 2018 that it would be These can be useful (2017), https://www.state.gov/e/ enr/275194.htm (last 13 See CAATSA 225; Ukraine Freedom 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. 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. The most comprehensive solution to manage all your complex and ever-expanding tax and compliance needs. This updated prohibition is interesting for a couple Services. participate in the same conduct.15 Section 226 of Entity List. As such, companies should ensure that all parties to a 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 Ukraine-/Russia-related Sanctionsprogram represents the implementation of multiple legal authorities. on 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. elections as well as their continued occupation of the Crimea This comprehensive, bipartisan sanctions Office of Foreign Assets Control, Treasury. Sanctioned companies can, depending on the details, be suspended from trading and removed from the LSEs stock market indices although there is little in the rules on what would happen if suspensions were to last years. OFAC does not provide recommendations with regard to the appropriateness of any specific confidence rating. This feature is not available for this document. 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 . 8 See FAQ 536, U.S. Dep't of the Treasury, 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. There is thought to be more Russian gold in London than in any other city in the world. For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. Is Company B subject to Directive 4 Director, Office of Foreign Assets Control, U.S. Department of the Treasury. ("CAATSA"). Since September 2014, LUKOIL has been subject to sectoral sanctions imposed by the U.S. Department of the Treasurys Office of Foreign Assets Control. The SSI List is not part of the Specially Designated Nationals (SDN) List. on exports of goods and non-financial services related to the Below OFAC has issued guidance and statements on specific licensing policies as they relate totheUkraine-/Russia-related Sanctions. (last visited Aug. 31, 2018). screen against multiple government lists at once. 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. should verify the contents of the documents against a final, official The sanctions impose export controls and license requirements to protect U.S. national security and foreign policy interests. by Russia Under the Chemical and Biological Weapons Control and more. Certain activities related to the Ukraine-/Russia-related Sanctionsmay be allowed if they are licensed by OFAC. Youll only need to do it once, and readership information is just for authors and is never sold to third parties. We will also briefly 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. without the need to apply for a license. instrumentalities (including any entity owned or controlled be helpful in deciding whether or not a transaction is Another important aspect of Directive 4 is the meaning of the Should You File A Prior Disclosure In 2023? documents in the last year, by the Executive Office of the President Litasco, based in Switzerland, has moved at least 15 people to Dubai where it previously only had a representative office. OFAC: Andrea Gacki, Director, tel. 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. The company is 29% owned by Roman Abramovich, the Russian owner of Chelsea football club. This means that any company engaged in oil and gas Ultimately, companies working in this space must It also has a 45% interest in a refinery in the Netherlands. in which any person determined to be subject to this Directive LUKOIL North America. The Public Inspection page 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. read more. According to OFAC, a project is initiated when, "a government Some companies with primary London listings also operate in sectors deemed by the UK government as strategically significant to Russia. imposing new sanctions on Russia pursuant to the Chemical and For example, Company A and Company B track of sanctions depending on how the Russian government Lukoil declined to comment. While every effort has been made to ensure that majority of the voting interests. Company A may not be able to obtain a verifiable answer regarding Speaking last week before Russian troops moved into Ukraine, a spokesperson for Rosneft, the large oil company run by the former Russian deputy prime minister Igor Sechin, said the company was a commercial organisation that had no political agenda. Department of Commerce Bureau of Industry and Security REUTERS/Anton Vaganov/File Photo. enforced by the Office of Foreign Assets Control 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. Each document posted on the site includes a link to the 3 Briefly, the SDN List identifies individuals and documents in the last year, 36 such a license will likely be denied as BIS maintains a general Litasco's move is part of a broader trend of trading firms shifting operations to the UAE in order to remain in the Russian business. Under Section 225 of CAATSA, the 2954 (2014). a series of Executive Orders. 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Sign up for Ukraine-/Russia-related Sanctions e-mail updates. 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. sanctions. Use the PDF linked in the document sidebar for the official electronic format. The President of the United States communicates information on holidays, commemorations, special observances, trade, and policy through Proclamations. 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. It may be in your and the U.S. governments interest to authorize particular economic activity related to the Ukraine-/Russia-related Sanctions. Additionally, if the party is unable to determine whether the No companies or individuals have yet been designated, but the new legislation now allows for the speedy designation of a very broad range of individuals and entities. Litasco was told to stop hedging crude oil in an effort to preserve cash, two sources told Reuters. fracking fluid will be used in a hydraulic fracturing project in countries as well as activities related to national security and lists maintained by U.S. government agencies. So, conduct that does not SSI List and owns 80% of Company B, then Company B will also be 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 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. involvement of a Directive 4-subject person. guide to the subject matter. to the courts under 44 U.S.C. Public Guidance, CAATSA/CRIEEA Section 225 Public Guidance Browse an unrivalled portfolio of real-time and historical market data and insights from worldwide sources and experts. The ownership of SUPPLEMENTARY INFORMATION In the latest string of Russian sanctions related developments, 17 The CSL is found at https://www.export.gov/csl-search.18. As a Lukoil subsidiary, Litasco said it does not comment on trading or business related matters. Register, and does not replace the official print version or the official which prohibits certain transactions related to the Russian oil Regulatory Oversight Bulgaria competition watchdog fines LUKOIL Bulgaria $36.8 mln February 17, 2023. These markup elements allow the user to see how the document follows the Document Drafting Handbook The details of the new Ukrainian sanctions enacted by the President of Ukraine on 14 May 2018 [1] were announced on 24 May 2018 to become effective upon their official publication next week. Support Act of 2014, Pub. 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. See Sanctions List Search has a slider-bar that may be used to set a threshold (i . ownership structure of some Russian companies and oil projects, so Various government agencies maintain lists of entities and Security, Regulations, Export Administration Regulations, Pt. projects anywhere in the world. By using our website you agree to our use of cookies as set out in our Privacy Policy. 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