Morgan Lewis US and Russia Sanctions Update
US Direct Sanctions - SDNS (cont'd)
Further recent SDN designations of note affecting Russia – though not under the Russian
sanctions regime
Trading affiliates of Rosneft: Feb.-March 2020 SDN designations, re Venezuela/PdVSA oil business
Rosneft's sale of all its Venezuela assets - after its two Swiss subs, Rosneft Trading S.A. and TNK Trading
International S.A., were SDN-designated in Feb.-March 2020 (along with RT's Chairman and President) for
buying/trading Venezuela crude
and then announcement that Rosneft was closing down these subs because of the SDN-related disruption
caused (and new Swiss trading co., Energopole S.A., has been established by Rosneft)
and follow-on vessel designation of Jan. 2021 (see slide 11)
Chinese state-owned shipping giant - SDN designations in Sept. 2019 under Iran sanctions regime
two specific subsidiaries sanctioned under EO 13846, for shipping Iranian crude oil
with a Russia-related effect: one of those two subs had a venture whose tankers were carrying Yamal LNG
product
in Jan. 2020 OFAC delisted that sub; thus, no more obstacle to dealing with it
note also related FAQs 804-807 issued in Nov. 2019 (only FAQS 804 and 805 have survived the Jan. 2020
delisting)
Further designations - per CAATSA sec. 224 (cyber / election interference, etc.), and various EOs
23 Oct., 23 Sept. and 10 Sept. 2020 designations (for malware/election interference)
15 July 2020 election-interference designations; and Sept. and Dec. 2019 designations; and several
more in previous few years
Several individuals and entities, mostly related to Crimea and the breakaway areas of eastern
Ukraine
Various Russian and other entities and persons, for Venezuela, Syria and North Korea sanctions
violations (oil shipments and others)
Against several Russian entities and individuals, for providing support for / enabling FSB
And likely more coming in spring 2021 re SolarWinds / other hacking etc.
Morgan Lewis
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