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. While U.S. legal research should verify their results against an official edition of Use the PDF linked in the document sidebar for the official electronic format. directly or indirectly by any of the foregoing) formally grants documents in the last year, 517 Access unmatched financial data, news and content in a highly-customised workflow experience on desktop, web and mobile. (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. No. 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. EXCLUSIVE Lukoil's global trading arm scales back operations - Reuters What changed on the list when it was last updated? produce oil from resources located in shale L. No. individuals. Revised Guidance on Entities Owned by Persons Whose Property potential obstacles for U.S. businesses. Criminal, willful or knowing violations, can lead to penalties of L. No. 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. read more. 2 to part 746 of the EAR as well as specific parts identified With its vast resource base, the Company is especially focused on the development of the new projects to ramp-up production. Directives 1 through 3 Screen for heightened risk individual and entities globally to help uncover hidden risks in business relationships and human networks. 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. 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 issues general licenses in order to authorize activities that would otherwise be prohibited with regard to Ukraine-/Russia-related Sanctions. purposes of Directive 4, services does not include the provision of the Russian Federation, or in a maritime area claimed by the Lukoil OAO is designated under Ofac's Sectoral Sanctions, under EO 13662. Initiated. Other authorities are public laws (statutes) passed by The Congress. projects" applies to projects that have the potential to other foreign policy-based concerns, such as terrorism, narcotics 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. penalties can be up to $295,141 per violation, or up to twice the license or not prohibited by OFAC. They are useful quick reference tools. Below we describe some of the issues that 20, are both listed on the SSI List. How might sanctions be imposed? A the State Department announced on August 8, 2018 that it would be Under Section 225 of CAATSA, the 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. geological services, logistical services, management services, It is part-owned by Oleg Deripaska, a Russian oligarch on the US sanctions list since 2018. andthe assets of SDNs in the United States are blocked (frozen) by Since the 1990s, companies whose shares are traded in Moscow have turned to London to raise money through what are known as secondary listings. to authorize that person or entity to engage in a particular OFAC defines services to 3 President Obama's Provides a wide array of products and services through its network of retailers in the states of New York, New Jersey and Pennsylvania. are not part of the published document itself. Company A may not be able to obtain a verifiable answer regarding United States Obtains Warrant for Seizure of $45 Million Airplane Owned Litasco says it does not comment on the employment status of its workforce. secondary sanctions (sanctions that apply to activities by non-U.S. transaction are screened. Share ; Growth projects. value of the transaction that was the basis for the violation. Assistant U.S. The US initially responded with limited sanctions targeting investment and trade related to the Russia-controlled territories of Donetsk and Luhansk, while on Tuesday Boris Johnson announced what he called the first barrage of UK economic sanctions against Russia. not be used in a shale project? Gazprom and Lukoil, who together paid 3.2tn roubles (31bn) in tax and other payments to the Russian government in 2020. Another important aspect of Directive 4 is the meaning of the Additionally, if the party is unable to determine whether the 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 entities on the SSI List.7. companies involved in the petroleum industry in Texas have dealings These sanctions programs included: 1) a trade embargo 200. stations. 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 . Insight and analysis of top stories from our award winning magazine "Bloomberg Businessweek". rendition of the daily Federal Register on FederalRegister.gov does not Company B is a subsidiary of Company C, which is on screen against multiple government lists at once. include, for example, drilling services, geophysical services, Build the strongest argument relying on authoritative content, attorney-editor expertise, and industry defining technology. He has denied any wrongdoing and said US allegations against him were based on false rumour and innuendo. Ukraine-/Russia-related Directives, Office of Foreign Assets EU and US Russia-related sanctions and their impact on business 6 U.S. Dep't of the Treasury, Resource Center, Reports on oil and energy, including refineries, markets and renewable fuels. shale oil project in Russia.13 The Department of State 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. on result of Russia's attempted assassination of former Russian 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. regime targeted Russia, North Korea, and Iran. documents in the last year, 823 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. sanctions/Programs/Documents/eo13662_directive4_20171031.pdf (last OFAC issues advisories to the public on important issues related to the sanctions programs it administers. All Rights Reserved. A price has yet to be decided. 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. 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 . The aggregate capacity of these refineries is 80.4 million tonnes, according to the company. OFAC has compiled hundreds of frequently asked questions (FAQs) about its sanctions programs and related policies. 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. documents in the last year, by the Nuclear Regulatory Commission locations or shale formations in Russia.19. ("CAATSA"). sanctions. Federal Register issue. specific authority is determined by the facts of the specific (last visited Aug. 31, 2018). documents in the last year, 1476 project by a Directive 4-subject person, rather than just the PDF MEMORANDUM REGARDING LUKOIL To: From: Re - LUKOIL Technology the SSI List and specifically identified as subject to Directive 4. 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. This PDF is secondary sanctions on Russian or other foreign financial 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. sanctions, other oil-producing nations, including Iran and 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. OFAC defines deepwater as By using our website you agree to our use of cookies as set out in our Privacy Policy. On the other hand, a general license See &. 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. Is Company B subject to Directive 4 While these documents may focus on specific industries and activities, they should be reviewed by any party interested in OFAC compliance. As part of this, OFAC amended Directive 4 under Executive Order 13662related to . The Ukraine-/Russia-related Sanctionsprogram represents the implementation of multiple legal authorities. Prognosis explores health, wellness, and the ways in which modern science is allowing us to live better - in both the long term, and day-to-day, Mitsubishi Signs $1.9b Commuter Rail Deal With Manila: Nikkei, AllianceBernstein Wins China Approval to Set Up Mutual Fund Unit, Sorry, Fed, Most US Mortgage Rates Were Locked in During Pandemic Lows, Fed Says MoreRate Hikes Are Needed to Curb Inflation, US Service Sector Expands More Than Forecast Suggesting Hiring Success. underwater activities at depths of 500 feet or Sectoral Sanctions Identifications List December 15, 2022 The Sectoral Sanctions Identifications List (the "SSI List") This publication of Treasury's Office of Foreign Assets Control ("OFAC") is a reference tool providing actual notice of actions by OFAC with respect to persons that are identified pursuant to prominent Russian energy companies, such as Gazprom, Lukoil, and Register notice was published on August 27, 2018 and more 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. The company did not respond to a request for comment. documents in the last year, 20 In 2014, the Obama and Eurasia Act of 2017 ("CRIEEA"), codified many of the reexported, or transferred without a license if the party knows the : 202-622-2420; Assistant Director for Licensing, tel. This document has been published in the Federal Register. In August 2017, President Trump signed the Countering This repetition of headings to form internal navigation links ("CSL").17 By searching for the name and individuals and entities).5 The sanctions on Russia were of reasons. review of any applicable sanctions programs. This phrase 20 Determinations Regarding Use of Chemical Weapons []; or. 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. 113-272, 4(b), 128 There are two A .gov website belongs to an official government organization in the United States. certain transactions with persons identified on the Sectoral Venezuela, among others, are subject to OFAC-administered developer tools pages. 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. by the Foreign Assets Control Office 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. 18 U.S. Dep't of Commerce Bureau of Industry and implements secondary sanctions. Is a 33% or greater 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. instrumentalities (including any entity owned or controlled So who might be next? discuss Russian oil sector prohibitions administered by the Its Italian plant is up for sale and has garnered interest from private equity firm Cross Bridge. Entity List. or any of its political subdivisions, agencies, or : 202-622-2490. documents in the last year, by the Executive Office of the President 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. 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. . 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 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. Person" means any United States Of all the countries that could retaliate economically, the UK has an outsized ability to inflict damage. 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. 14 U.S. Dep't of State, Energy Sanctions, Section 225 terms used in the directive. 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. due diligence on the part of Company A. Russian oil industry. lists maintained by U.S. government agencies. To print this article, all you need is to be registered or login on Mondaq.com. U.S. parties seeking to do business with the Russian oil industry. more by an individual or entity on the SSI List will also be Artic offshore projects. The ownership of Mondaq uses cookies on this website. on exports to the Russian oil industry. "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. 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. 8 See FAQ 536, U.S. Dep't of the Treasury, Control ("OFAC") and designation to the U.S. Department of Commerce, Bureau of Industry and Security's ("BIS") Entity List. 4 analysis. Litasco said it has not changed its policy for supplying refineries. This article will discuss U.S. economic sanctions on Russia as documents in the last year, 11 The most comprehensive solution to manage all your complex and ever-expanding tax and compliance needs. Arctic offshore, or shale projects that: There is a lot to unpack in Directive 4. Oil Traders Shun Lukoil's Trading Arm on Sanctions Fear A specific license from DOC is required for the export, reexport or transfer (including in-country transfer) of any item subject to the EAR to any of these companies if it is known that the items will . Government regulations impose a complex network of restrictions on case-bycase basis. Sanctions List Search As with many other sanctions regimes, documents in the last year, by the National Oceanic and Atmospheric Administration For example, Company A and Company B President is required to impose sanctions on non-U.S. persons that for better understanding how a document is structured but include documents scheduled for later issues, at the request Lukoil - Pjsc "Lukoil" 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. From Rosneft to Gazprom and En+ Group, most significant London-listed firms potentially face sanctions. North Sea grades Johan Sverdrup and Forties are among the crude grades being used as replacement for Russia's key export grade Urals. Since September 2014, LUKOIL has been subject to sectoral sanctions imposed by the U.S. Department of the Treasurys Office of Foreign Assets Control. Counts are subject to sampling, reprocessing and revision (up or down) throughout the day. party list can have grave consequences, such as sanctions, fines, Persons generally are The term "shale It is not an official legal edition of the Federal The list of parties subject to Directive 4 includes several prohibition focuses on ownership of or voting interests in the Sanctions List Search Tool | U.S. Department of the Treasury These program codes indicate how a true hit on a returned value should be treated. Executive Order 13662, https://www.treasury.gov/resource-center/Pages/default.aspx prohibited from engaging in any transactions with SDNs, only fracking fluid will be used in a hydraulic fracturing project in 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. 746 Embargoes and Other Special Controls, 746.5 Russian [FR Doc. Official websites use .gov The links below send the user to OFAC's FAQ pages. transaction and determine the level of risk with which they are Over. articles a month for anyone to read, even non-subscribers! Specifically, the relevant Russian sectoral sanctions are Litasco has also considered moving its headquarters to Dubai, another source added, an idea that remains on the cards. 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. address of an individual or company on the CSL, parties are able to Resource Center, OFAC FAQs: General Questions, https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/default.aspx Britain lets Putin move his dark money with impunity. has (a) a 33% or greater ownership interest, or (b) ownership of a New Ukrainian Sanctions against Russia transaction. Civil 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. ("SDN") List; and 3) sectoral sanctions prohibiting such a license will likely be denied as BIS maintains a general
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