The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 10 Jan 2025 (UK):
The Office of Financial Sanctions Implementation ("OFSI") designated two entities under the Russia sanctions regime, pursuant to the Russia (Sanctions) (EU Exit) Regulations 2019.
- 10 Jan 2025 (UK):
The Office of Financial Sanctions Implementation ("OFSI") issued General Licence INT/2025/5635701 (the "GL"), pursuant to the Russia (Sanctions) (EU Exit) Regulation 2019. The GL allows for a wind-down period of positions involving Gazprom Neft and PJSC Surgutneftegas (the "DPs"), or any entity owned or controlled, directly or indirectly, by the DPs ("Subsidiary").
- 10 Jan 2025 (UK):
The Office of Financial Sanctions Implementation ("OFSI") issued General Licence INT/2025/5635700 (the "GL") in respect of continued business operations with Gazpromneft-Sakhalin LLC and any entity owned or controlled, directly or indirectly, by Gazpromneft-Sakhalin LLC (together, the "Relevant Subsidiary"), to the extent such operations are related to the projects listed in Schedule 1 of the GL (the "Exempt Projects").
- 10 Jan 2025 (OFAC):
The U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") designated 37 individuals, 203 entities, and 184 vessels, and the U.S. Department of State designated more than 150 individuals and entities. The designations (which include some of Russia's largest energy companies) were done pursuant to Russia-related Executive Order ("E.O.") 14024 and, in some cases, E.O. 13662 (for which the lifting of sanctions implicates the congressional review provisions of the Countering America's Adversaries Through Sanctions Act ("CAATSA")).
OFAC's designations include entities linked to Russia's third-largest oil producer Public Joint Stock Company Gazprom Neft, entities linked to LNG project Limited Liability Arctic LNG 2, and entities linked to Russian oil and gas company Surgutneftegas. This action targets companies and individuals involved in shipping services, energy trading, oil refining, vessel monitoring, and financial services firms supporting Russia's oil and gas industry.
The U.S. Department of State's designations include the board of directors and senior officials of Rosatom, a Russian state corporation specializing in nuclear energy. The designations specifically target Russia's energy revenues, such as Russian Liquified Natural Gas (LNG) export terminals, the operator of the Vostok Oil project, entities materially supporting U.S.-designated SOVCOMFLOT and Arctic LNG 2 Project, and oilfield service providers. In addition, this action targets entities that have operated or operate in Russia's metals and mining industry.
Concurrent with the designations, OFAC also issued (i) a Determination pursuant to E.O. 14024, authorizing the imposition of sanctions for persons operating in the "energy sector of the Russian Federation" and, (ii) a Determination pursuant to E.O. 14071, imposing a prohibition (effective February 27, 2025) on the exportation of "petroleum services" to any person located in the Russian Federation.
Concurrent with these designations, OFAC issued a total of eight new or amended Russia-related General Licenses ("GLs"): GL 8L (authorizing blocked bank involvement in Russia-related energy transactions) was reissued as a "wind down" license with a moved up expiration date vis-à-vis GL 8K; the pre-existing "civil nuclear energy" GL (115) was reissued as GL 115A to add the list of banks that had previously appeared on GL 8K; GL 117 authorizes wind-down transactions involving certain newly blocked entities; GL 118 authorizes the divestment of debt and equity of certain newly blocked entities; GL 120 authorizes certain transactions involving newly blocked vessels; GL 119 authorizes "transactions involving Public Joint Stock Company Gazprom Neft related to diplomatic and consular mission operations outside Russia"). OFAC also issued GL 121, authorizing transactions related to certain projects that will be prohibited by the new petroleum services determination. In addition to the above-mentioned GLs that license against prohibitions incorporated into the Russian Harmful Foreign Activities Sanctions ("RuHSR"), OFAC issued GL 26 to authorize, with respect to certain newly blocked persons blocked pursuant to both E.O. 14024 and E.O. 13622, transactions prohibited by the Ukraine-/Russia-Related Sanctions Regulations that are authorized pursuant to the RuHSR. OFAC also revoked a license authorizing transactions involving previously non-designated SOVCOMFLOT vessels (GL 93).
OFAC published five new FAQs (1213-1217) about the petroleum services determination, energy sector determination, and GL 26, and amended 14 Russia-related FAQs (967, 976, 977, 978, 999, 1011, 1012, 1017, 1117, 1126, 1182, 1183, 1201, and 1203).
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