US Sectoral Sanctions
US Direct Sanctions - SDNS (cont'd)
SDN Delistings
Further notes re SDN delisting:
-
The Deripaska companies' delistings were based in large part on the unintended
consequences of the SDN designations for the US (and world) aluminum market etc. -
and thus may well not be readily achieved by other Russian SDNS
Deripaska's GAZ Group (automotive giant) might eventually be SDN-delisted upon
ownership restructuring etc. (see slide 10 re the most recent and unusual GL extension
to 22 Jan. 2021 - and see slide 39 for interpretation of such GLs)
Still pending Vekselberg and Deripaska US court challenges against their OFAC SDN
designations / consequences (see slide 10 above re more recent status of both)
Vekselberg- and Renova-linked US investment management cos. and GP entities, which are not
SDNs but whose assets and related proceeds were blocked because of Vekselberg/Renova majority
ownership of asset-holding entities, filed complaint in US federal court in 2019 - basically
challenging OFAC's 50% rule as applied to them - case dismissed Sept. 2020 (see slide 10)
Deripaska also filed a complaint in US federal court in 2019 challenging his SDN designation
And note Russian-American physicist/entrepreneur V. Gapontsev's successful legal
challenge to his 2018 OFAC "Oligarch List" designation - seems a special case: notified by
OFAC Sept. 2019 letter that he is not an oligarch in the Russian Federation for purposes of
Section 241 of CAATSA" (see slides 10, 56-57); this lifted cloud from him and his Mass.-
based company IPG Photonics
And also March 2020 delisting of Khudainatov's Independent Petroleum Co. (NNK)
Morgan Lewis
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