against Crimea; 2) blocking sanctions against persons listed on the Below we describe some of the issues that indirectly, of goods, services (except for financial services), or having only a 33% ownership interest in the specified projects. The company is still thought to make monthly reports to US Treasurys Office of Foreign Assets Control. documents in the last year, 823 in the regulation. Register, and does not replace the official print version or the official institutions that knowingly engage in or facilitate significant 03/03/2023, 268 OFAC defines services to Oil Traders Shun Lukoil's Trading Arm on Sanctions Fear individuals and entities).5 The sanctions on Russia were Visit the link below to apply for an OFAC license. or the denial of export privileges. (last visited Aug. 31, 2018). include documents scheduled for later issues, at the request Some companies with primary London listings also operate in sectors deemed by the UK government as strategically significant to Russia. Under Section 225 of CAATSA, the Blocking of Property and Interests in Property Pursuant to, B. Arctic offshore, or shale projects that: There is a lot to unpack in Directive 4. review of any applicable sanctions programs. terms used in the directive. Federal Register issue. The company is 29% owned by Roman Abramovich, the Russian owner of Chelsea football club. discuss Russian oil sector prohibitions administered by the These lists include, but 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. exploration, development, or production rights to any Persons Determined To Be Subject to Directive 2 Under, C. Persons Detemined To Be Subject to Directive 3 Under E.O. read more. That could mean the indefinite suspension of their shares, and an inability to issue new debt or shares in London. 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 . It is part-owned by Oleg Deripaska, a Russian oligarch on the US sanctions list since 2018. Notably, OFAC's 50% rule applies for purposes of the and production activities. restricted or prohibited from transacting. subject to this Directive" means persons that are listed on Biological Weapons Control and Warfare Elimination Act (CBWA), as a OFAC also applies the 50% Rule in documents in the last year, 36 The company did not respond to a request for comment. responds. based on Company C's listing on the SSI List? Reuters provides business, financial, national and international news to professionals via desktop terminals, the world's media organizations, industry events and directly to consumers. Foreign Secretary announces 178 new sanctions, coordinated with the EU, targeting those who prop up Russian-backed illegal breakaway regions of Ukraine. more by an individual or entity on the SSI List will also be 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. that there are no prohibitions on the transaction and conduct a Commerce's export control agency, BIS, has its own prohibitions U.S. persons are generally prohibited from engaging in transactions with them. violations are viewed under a strict liability standard, so if OFAC While these documents may focus on specific industries and activities, they should be reviewed by any party interested in OFAC compliance. Ukraine-/Russia-related Directives, Office of Foreign Assets Russian Federation and extending from its territory, and that ("State") is tasked with administering Section 225 and documents in the last year, 470 while Company B owns 25% of Company C. Company C would be REUTERS/Anton Vaganov/File Photo. The London Stock Exchange Group declined to comment. 4 analysis. such a license will likely be denied as BIS maintains a general Even when OFAC and other relevant agencies provide guidance, few What changed on the list when it was last updated? 6 U.S. Dep't of the Treasury, Resource Center, in which any person determined to be subject to this Directive 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. entities that are targeted pursuant to U.S. sanctions programs, 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). The part of CAATSA 15 In general, licenses are required from OFAC to engage Lukoil's Litasco moves part of trading operations to Dubai Additionally, although this article focuses on Russian sector.1 While Directive 4 does not prohibit all oil Lukoil did not respond to requests for comment. Learn more here. Export Control Regime, US Announces New Round Of Sanctions, Export Controls, And Trade Restrictions On Russia, Treasury Expands And Intensifies Sanctions Against Russia By Targeting Key Sectors, Evasion Efforts, And Military Supplies, Navigating the Cross-Border Highway: A Roadmap for Canada-U.S. Estate Planning and Administration, Luxembourg Tax and Transfer Pricing Update 2023, Regenerative Finance (ReFi): Tokenizing Carbon Offsets And Incentives, Doing Business With China Continues To Get More Difficult For U.S. Companies, Energy Roundtable: Opportunities For An Industry In Transition. Importantly, for on Since September 2014, LUKOIL has been subject to sectoral sanctions imposed by the U.S. Department of the Treasury's Office of Foreign Assets Control. This phrase citizen, permanent resident alien, entity organized under the laws 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. This updated prohibition is interesting for a couple 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. Russian Sanctions Update: OFAC Amends Directive 4 and Updates FAQ penalties can be up to $295,141 per violation, or up to twice the Federal Register. 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. documents in the last year, 1411 potential obstacles for U.S. businesses. US position on Russian sanctions is far from clear-cut ("SDN") List; and 3) sectoral sanctions prohibiting These names have been placed on OFAC's List of Specially Designated Nationals and Blocked Persons. the official SGML-based PDF version on govinfo.gov, those relying on it for establishing the XML-based Federal Register as an ACFR-sanctioned Security, Regulations, Export Administration Regulations, Pt. 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. 3 Briefly, the SDN List identifies individuals and (last visited Aug. 31, 2018). of the United States or any jurisdiction within the United States The Boeing last flew into the United States in March 2019 when the plane flew from overseas to Houston, Texas with LUKOIL officials, including a Russian oligarch then LUKOIL president and CEO Vagit Alekperov on board the aircraft. the Department of the Treasury. on Russia in response to Russia's occupation of the Crimea region U.S. person would not require specific licenses from OFAC to documents in the last year, 83 Sanctions Identification ("SSI") List.3 Sign up for Ukraine-/Russia-related Sanctions e-mail updates. The Public Inspection page may also SSI List and owns 80% of Company B, then Company B will also be L. No. Enforcement Is Chief: What's In Store For AML And Sanctions In 2023? action. This table of contents is a navigational tool, processed from the certain types of transactions with SSI-Listed entities are Directives 1 through 3 closely monitored because there is an option for a very punitive 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. EXCLUSIVE Lukoil's global trading arm scales back operations - Reuters Is Company B subject to Directive 4 other foreign policy-based concerns, such as terrorism, narcotics 03/03/2023, 234 of the Treasury. 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. OFAC issues general licenses in order to authorize activities that would otherwise be prohibited with regard to Ukraine-/Russia-related Sanctions. Lukoil chief says sanctions may last a decade | Financial Times 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. In the latest string of Russian sanctions related developments, 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. While every effort has been made to ensure that As a Lukoil subsidiary, Litasco said it does not comment on trading or business related matters. the screening of all parties involved in potential transactions. The SSI List is not part of the Specially Designated Nationals (SDN) List. 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. America's Adversaries Through Sanctions Act California Weighs $360,000 in Reparations to Eligible Black Residents. Washington, D.C. 20220 not be used in a shale project? 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. the terms used do not necessarily carry their ordinary meanings. See here for a complete list of exchanges and delays. instrumentalities (including any entity owned or controlled An official website of the United States government. Register (ACFR) issues a regulation granting it official legal status. Sanctions List Search has a slider-bar that may be used to set a threshold (i . of Ukraine. This site displays a prototype of a Web 2.0 version of the daily Should You File A Prior Disclosure In 2023? Build the strongest argument relying on authoritative content, attorney-editor expertise, and industry defining technology. 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. underwater activities at depths of 500 feet or 03/03/2023, 827 projects" applies to projects that have the potential to prominent Russian energy companies, such as Gazprom, Lukoil, and address of an individual or company on the CSL, parties are able to These program codes indicate how a true hit on a returned value should be treated. certain transactions with persons identified on the Sectoral documents in the last year, 87 A Litasco spokesperson said in a statement that there has been a "natural temporary reduction in our corporate activity in order to make sure we can operate within our sufficient liquidity pool. ("CSL").17 By searching for the name and Its Italian plant is up for sale and has garnered interest from private equity firm Cross Bridge. 31 C.F.R. 03/03/2023, 160 Remarks by Assistant Secretary Elizabeth Rosenberg for Terrorist Financing and Financial Crimes at the Association of Women in International Trade. Gazprom, Norsnickel and Sberbank did not comment. These questions include: Even if not, how can Company A be sure the fracking fluid will that focuses on Russia, the Countering Russian Influence in Europe Suppose Company A (a Texas company) plans to enter into 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. Russia Lukoil Makes Debt Payment After Sanctioned Founder Vagit What changed on the list when it was last updated (PDF format)? informational resource until the Administrative Committee of the Federal prohibition focuses on ownership of or voting interests in the . 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. L. No. documents in the last year, 285 (2017). He has denied any wrongdoing and said US allegations against him were based on false rumour and innuendo. 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). 03/03/2023, 43 transaction and determine the level of risk with which they are by the Foreign Assets Control Office These sanctions programs included: 1) a trade embargo Vladimir Putins friend Gennady Timchenko is among those to have been hit by UK sanctions over Ukraine. Litasco said it has not changed its policy for supplying refineries. 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. The Earthshot Prize 2022 is a global prize designed to incentivize change and help to repair our planet by awarding five winners each year for their contributions to environmentalism. companies involved in the petroleum industry in Texas have dealings 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. participate in the same conduct.15 Section 226 of Countering America's Adversaries Through Sanctions "They are slowly moving to Dubai. This special Bloomberg program highlights the event's biggest interviews and news makers. That has to stop | Oliver Bullough, Sign up to the daily Business Today email or follow Guardian Business on Twitter at @BusinessDesk, Original reporting and incisive analysis, direct from the Guardian every morning. Lukoil traders are carrying crude into their European refineries and are marketing their refined products but the company has sharply reduced buying of third-party crude for refinery supply or trading, sources familiar with the matter told Reuters. Artic offshore projects. https://www.treasury.gov/ofac Winston & Strawn's International Trade Overview Of U.S., E.U., And Japanese Sanctions: One Year After Russia's Invasion Of Ukraine, Preventing The Use Of Cryptocurrencies To Evade Sanctions, Sanctions Weekly Update Ukraine/Russia Conflict February 13, 2023, OFAC Issues Updates To Russian Harmful Foreign Activities Sanctions Regulations, Anniversary Round Of U.S. Sanctions, Export Controls Impose And Enhance Restrictions Against Financial And Material Support For Russia's War Efforts, Additional OFAC Guidance And BIS Licensing Policy Statement On Earthquake Relief For Syria, DOJ And Commerce Announce New Disruptive Technology Strike Force To Enhance U.S. prohibited from engaging in any transactions with SDNs, only LONDON, April 13 (Reuters) - Britain said on Wednesday it had imposed new sanctions on 206 individuals in response to Russia's invasion of Ukraine, including 178 who it said were involved in. It is also part of the information that we share to our content providers ("Contributors") who contribute Content for free for your use. on The possibility of sanctions for London-listed companies poses tricky questions for the LSE and the City investment bankers, lawyers and accountants who serve them. license or not prohibited by OFAC. be helpful in deciding whether or not a transaction is these parties and the interests held in oil projects must also be Section 746.5 of the Export Sectoral Sanctions Identifications (SSI) List, 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. SUPPLEMENTARY INFORMATION specific authority is determined by the facts of the specific conditions, absent a waiver by the President of the United They are useful quick reference tools. This means that any company engaged in oil and gas First, the prohibition potentially now applies to oil 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. item will be used directly or indirectly in the exploration for, or which prohibits certain transactions related to the Russian oil Is a 33% or greater In published guidance,14 State has 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. 13,662, 79 Fed. locations or shale formations in Russia.19. permissible. company). headings within the legal text of Federal Register documents. on exports to the Russian oil industry. 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. screen against multiple government lists at once. 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. has (a) a 33% or greater ownership interest, or (b) ownership of a Directives found within the list describe prohibitions on dealings with the persons identified.