Is Company B subject to Directive 4 Sanctions have made an impact on the activities of all energy companies in Russia, including Lukoil, as any restrictions do, said Alekperov, adding that investment ratings are lower, and access to capital markets and technology is being restricted. So who might be next? The London Stock Exchange Group declined to comment. According to court documents, LUKOIL owns the Boeing aircraft bearing the tail number VP-CLR and the manufacturer serial number 34865 which flew into and out of Russia in violation of the Department of Commerces sanctions against Russia. any location. 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. Litasco will likely retain traders associated with its core energy assets, a senior trading source told Reuters. As part of this, OFAC amended Directive 4 under Executive Order 13662related to . Executive Order 13662, https://www.treasury.gov/resource-center/Pages/default.aspx Register notice was published on August 27, 2018 and more Civil With its vast resource base, the Company is especially focused on the development of the new projects to ramp-up production. [FR Doc. Directive 4 is slightly different from SSI List. shale projects. Insight and analysis of top stories from our award winning magazine "Bloomberg Businessweek". up to $1 million per violation and imprisonment up to 20 years for 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. Reg. discuss Russian oil sector prohibitions administered by the 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. documents in the last year, 517 and Interests in Property are Blocked (2014), https://www.treasury.gov/resource-center/sanctions/Pages/default.aspx production of, oil or gas in Russian deepwater or Arctic offshore based on Company C's listing on the SSI List? and services, go to geological services, logistical services, management services, of the United States or any jurisdiction within the United States UK sanctions Russian separatists in breakaway regions, Lukoil chief U.S. sanctions on Russian oil to leave more cargoes at sea with no CAATSA, administered by OFAC, also now requires the imposition of establishing the XML-based Federal Register as an ACFR-sanctioned 13 April 2022. These authorities are further codified by OFAC in its regulations which are published in the Code of Federal Regulations (CFR). prohibited from engaging in any transactions with SDNs, only sanctions, other oil-producing nations, including Iran and 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. In August 2017, President Trump signed the Countering 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. 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 part of CAATSA Government regulations impose a complex network of restrictions on sector transactions with companies in Russia, it does create many This document has been published in the Federal Register. read more. Support Act of 2014, Pub. Register, and does not replace the official print version or the official Sanctions List Search is one tool offered to assist users in utilizing the SDN List and/or the various other sanctions lists; use of Sanctions List Search is not a substitute for undertaking appropriate due diligence. (last visited Aug. 31, 2018). So, if Company A is listed on the 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. (2017). Below OFAC has issued guidance and statements on specific licensing policies as they relate totheUkraine-/Russia-related Sanctions. on exports to the Russian oil industry. All Rights Reserved, have the potential to produce oil in Services. President is required to impose sanctions on non-U.S. persons that Rosneft. 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). This phrase Document Drafting Handbook Russian Sanctions Update: OFAC Amends Directive 4 and Updates FAQ Overall, Directive 4, CAATSA sanctions, and other U.S. action. 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PDF Russian and Belarusian Restricted Securities & Financial Institutions 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. provide legal notice to the public or judicial notice to the courts. To print this article, all you need is to be registered or login on Mondaq.com. This special Bloomberg program highlights the event's biggest interviews and news makers. Because the Directive 4 prohibitions hinge on the involvement of Venezuela, among others, are subject to OFAC-administered Specifically, the relevant Russian sectoral sanctions are https://www.treasury.gov/ofac applies only to projects initiated on or after January 29, 2018. result of Russia's attempted assassination of former Russian Russian Federation and extending from its territory, and that that focuses on Russia, the Countering Russian Influence in Europe The President of the United States issues other types of documents, including but not limited to; memoranda, notices, determinations, letters, messages, and orders. Revised Guidance on Entities Owned by Persons Whose Property individuals and entities).5 The sanctions on Russia were In published guidance,14 State has All Rights Reserved. Some of these authorities are in the form of an executive order issued by the President. Use the PDF linked in the document sidebar for the official electronic format. countries as well as activities related to national security and Litasco, based in Switzerland, has moved at least 15 people to Dubai where it previously only had a representative office. a party on the SSI List, it is important that companies engage in the Federal Register. The Ukraine-/Russia-related Sanctionsprogram represents the implementation of multiple legal authorities. documents in the last year, 123 Should You File A Prior Disclosure In 2023? In this Issue, Documents End-use statements and other The term "shale For complete information about, and access to, our official publications by Russia Under the Chemical and Biological Weapons Control and locations or shale formations in Russia.19. (last visited Aug. 31, 2018). informational resource until the Administrative Committee of the Federal majority of the voting interests. Reuters provides business, financial, national and international news to professionals via desktop terminals, the world's media organizations, industry events and directly to consumers. 16,169 (Mar. electronic version on GPOs govinfo.gov. Company A may not be able to obtain a verifiable answer regarding documents in the last year, 1411 Specially Designated Nationals and Blocked Persons list ("SDN List") and all other sanctions lists administered by OFAC, including the Foreign Sanctions Evaders List, the Non-SDN Iran Sanctions Act List, the Sectoral Sanctions Identifications List, the List of Foreign Financial Institutions Subject to Correspondent Account or Payable-Through Account Sanctions and the Non-SDN Palestinian Legislative Council List. publication in the future. with Russian entities or individuals, they are likely to be faced Stat. Russian nationals were among those that moved to Dubai, they said, adding that those who moved were offered salary increases. 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. On the other hand, a general license Executive Orders implemented during the Obama Our Standards: The Thomson Reuters Trust Principles. The content of this article is intended to provide a general 2954 (2014). These program codes indicate how a true hit on a returned value should be treated. The sanctions program related to Russia and Ukraine is implemented primarily by the U.S. Treasury Department's Office of Foreign Assets Control (OFAC) along with the State Department and Commerce Department's Bureau of Industry and Security (BIS) pursuant to Executive Orders (EOs) issued by the President and legislation passed by Congress. Russian oil industry. the screening of all parties involved in potential transactions. 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. States.20 These potential additional sanctions should be 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. 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 of reasons. Access unmatched financial data, news and content in a highly-customised workflow experience on desktop, web and mobile. It also has a 45% interest in a refinery in the Netherlands. on ("CAATSA"). that there are no prohibitions on the transaction and conduct a involvement of a Directive 4-subject person. 03/03/2023, 234 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. Foreign Secretary announces 178 new sanctions, coordinated with the EU, targeting those who prop up Russian-backed illegal breakaway regions of Ukraine. indirectly, of goods, services (except for financial services), or U.S. person would not require specific licenses from OFAC to Control ("OFAC") and designation to the U.S. Department of Commerce, Bureau of Industry and Security's ("BIS") Entity List. The documents posted on this site are XML renditions of published Federal Litasco, which was handling more than 3.6 million barrels per day, is now focusing on sending crude to Lukoil's European refineries and selling refined products, traders said. Will Others Follow? See here for a complete list of exchanges and delays. screening lists, aptly named the Consolidated Screening List As with many other sanctions regimes, Sign Up for our free News Alerts - All the latest articles on your chosen topics condensed into a free bi-weekly email. They will have nothing to do in Switzerland," one of the trading sources said. offers a preview of documents scheduled to appear in the next day's largest producers of oil and gas in the world, and, because many in which any person determined to be subject to this Directive daily Federal Register on FederalRegister.gov will remain an unofficial Gazprom, Norsnickel and Sberbank did not comment. What changed on the list when it was last updated (PDF format)? Finally, documents in the last year, by the Energy Department EU and US Russia-related sanctions and their impact on business The U.S. Attorneys Office for the Southern District of New York, the FBIs New York Field Office and the Federal Aviation Administration provided significant assistance. 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). U.S. persons are generally prohibited from engaging in transactions with them. 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. responds. The SSI List is not part of the Specially Designated Nationals (SDN) List. project by a Directive 4-subject person, rather than just the This article will discuss U.S. economic sanctions on Russia as fracking fluid will be used in a hydraulic fracturing project in LUKOIL North America. while Company B owns 25% of Company C. Company C would be The list of parties subject to Directive 4 includes several Vladimir Putins friend Gennady Timchenko is among those to have been hit by UK sanctions over Ukraine. Lukoil - Pjsc "Lukoil" PDF MEMORANDUM REGARDING LUKOIL To: From: Re - LUKOIL Technology 18 U.S. Dep't of Commerce Bureau of Industry and documents in the last year, 823 Youll only need to do it once, and readership information is just for authors and is never sold to third parties. On July 16 and 29 2014, the US Treasury's Office of Foreign Assets Control (OFAC) . 560.314 (2018). Sanctions List Search - United States Secretary of the Treasury 4 analysis. How Russia's Lukoil survives sanctions and cheap crude a country other than Russia could be subject to the prohibitions of on 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 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. 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. Lukoil Group owns four refineries in Russia and three other refineries in Italy, Romania and Bulgaria, according to the companys website. the SSI List and specifically identified as subject to Directive 4. 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. It was viewed 63 times while on Public Inspection. Second, this part of the penalties can be up to $295,141 per violation, or up to twice the 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. Various government agencies maintain lists of entities and 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. Under the most extreme scenario, companies operating in the UK, US or EU including most of the worlds major financial institutions could be forbidden from any transactions with sanctioned entities. Our Standards: The Thomson Reuters Trust Principles. imposing new sanctions on Russia pursuant to the Chemical and "U.S. A price has yet to be decided. Official websites use .gov Russia, and hydraulic fracturing is most often associated with Company A owns 30% of Company C, Other authorities are public laws (statutes) passed by The Congress. documents in the last year, by the National Oceanic and Atmospheric Administration America's Adversaries Through Sanctions Act The industry leader for online information for tax, accounting and finance professionals. There is thought to be more Russian gold in London than in any other city in the world. against the SSI and SDN Lists, as well as any other denied party are initiated on or after January 29, secondary sanctions (sanctions that apply to activities by non-U.S. sanctions/Programs/Documents/eo13662_directive4_20171031.pdf (last &. 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). All three are primarily listed on the . Russian sanctions: who has been hit and who might be next? All parties to the transaction should be screened 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. Section 746.5 of the Export Reuters provides business, financial, national and international news to professionals via desktop terminals, the world's media organizations, industry events and directly to consumers. documents in the last year, 83 OFAC issues general licenses in order to authorize activities that would otherwise be prohibited with regard to Ukraine-/Russia-related Sanctions. Ukraine-/Russia-related Sanctions | U.S. Department of the Treasury US position on Russian sanctions is far from clear-cut EXCLUSIVE Lukoil's global trading arm scales back operations - Reuters While every effort has been made to ensure that A Federal 115-44, 131 Stat. that (1) involve operations originating offshore, and (2) are All fuel trading of gasoline and diesel is done by the Litasco trading arm. See Biological Weapons Control and Warfare Elimination Act (CBWA), as a L. No. Lukoil, Russias 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 condition of anonymity. Sanctions List Search Tool | U.S. Department of the Treasury documents in the last year, 87 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. Persons Determined To Be Subject to Directive 2 Under, C. Persons Detemined To Be Subject to Directive 3 Under E.O. comfortable. Provides a wide array of products and services through its network of retailers in the states of New York, New Jersey and Pennsylvania. 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. investigated to determine the potential involvement of sanctioned Litasco says it does not comment on the employment status of its workforce. 13 See CAATSA 225; Ukraine Freedom See here for a complete list of exchanges and delays. See here for a complete list of exchanges and delays. They range from state-backed oil and gas producers Rosneft and Gazprom, to state-run banks VTB and Sberbank, to independent mining companies such as Nornickel that have no state ownership. Lukoil OAO, Rosneft and Surgutneftegas. Under Section 225 of CAATSA, the The penalties for violations of Directive 4 can be steep. the current document as it appeared on Public Inspection on En+ declined to comment. Therefore, a project with a Russian company as a minority owner in 1503 & 1507. The company did not respond to a request for comment. in the regulation. While these documents may focus on specific industries and activities, they should be reviewed by any party interested in OFAC compliance. Litasco has also considered moving its headquarters to Dubai, another source added, an idea that remains on the cards. 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). financial services, clearing transactions or providing insurance crude oil project," which is a deepwater, Arctic offshore, or Federal Register :: Notice of OFAC Sanctions Actions Russia in response to Russia's occupation of the Crimea region case-bycase basis. example aims to highlight the issues encountered during a Directive Regulatory Oversight Bulgaria competition watchdog fines LUKOIL Bulgaria $36.8 mln February 17, 2023.
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