Morgan Lewis US and Russia Sanctions Update
EU Sectoral Sanctions (cont'd)
Energy (cont'd)
Restricted activities include (per Reg. art. 3a, as amended Dec. 2014):
Provision, directly or indirectly, of specified types of "associated services necessary for"
deepwater, Arctic offshore, shale oil E&P projects (same litany-detail as for art. 3 - see slide
72 above) in Russia including in its EEZ and Continental Shelf (again note uncertainty re
Russia's Caspian zone):
these specified types of services:
•
drilling
•
completion services
•
well testing
·
logging
•
supply of specialised floating vessels*
[* Note: EU Guidance Note FAQ 10 exempts "supply vessels such as platform supply vessels, anchor handling tug and supply vessels
or emergency response vessels"]
and the same exceptions apply for
execution of an obligation arising from a prior (pre-12 Sept. 2014) contract / agreement or follow-on ancillary
contracts, or
services necessary in case of certain events threatening health, safety or environment
again, otherwise apparently no scope for authorization here - rather, a pure prohibition for / to all
(if neither of the above two carve-outs applies)
but may be attainable for activities (per Reg. arts 3 or 3a) in shallow-water portion of mixed
shallow/deep water field?
Morgan Lewis
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