US Sectoral Sanctions
US Sectoral Sanctions - BIS (cont'd)
Export / Reexport Restrictions (cont'd)
Further, the same five OFAC-designated Russian energy companies (per OFAC Directive 4)
have been on the BIS "Entity List" since Sept. 2014
•
⚫ Gazprom
•
Gazpromneft
•
⚫ Lukoil
•
Rosneft
•
Surgutneftegas
Plus 15 specifically named Rosneft subs since 2015 and 51 named Gazprom subs since 2016
(essentially the same as those named by OFAC)
Also likely (but not automatically) applies to some other owned or controlled subs - see BIS
Entity List FAQ 134 (depends on nature of sub / its activities, control, and other factors)
This specific Entity List designation imposes (re these companies, and at least several subs)
- see slide 21
-
A new license requirement for export, reexport, or transfer of "all items subject to the EAR"
for the 5 initially named energy sector companies (and likely also most of their subs)
when used in Russian deepwater, Arctic offshore, or shale projects
and now also at least for all the named Rosneft and Gazprom subs
If... or if... (the same previous-slide first-bullet oil/gas target projects litany applies here - and the
rules of (i) denial presumption for oil projects, and (ii) condensate = oil, are applied here too)
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Morgan Lewis
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