Morgan Lewis US and Russia Sanctions Update
EU Sectoral Sanctions (cont'd)
Energy (cont'd)
But authorization shall not be granted for supply etc. of Annex II items
if reasonable grounds to determine that is for Russian oil (incl. condensate?) E&P projects:
in waters deeper than 150 meters (circa 492 feet)
in offshore areas north of the Arctic Circle
in shale formations by way of hydraulic fracturing (but not including E&P activities through
shale formations to locate/extract oil from non-shale reservoirs)
except for
execution of obligation arising from contract concluded before 1 Aug. 2014 - or, per Dec. 2014
liberalization, from "ancillary contracts necessary for the execution of such contracts", or
items necessary in case of certain events threatening health, safety or environment
in fact, there have been many such license applications / approvals since 2014 to date (for
European and US companies, and EU subsidiaries / JVs of Russian energy companies)
and further note - EU has not followed US CAATSA / OFAC Directive 4 expansion of coverage to
any such project worldwide having ≥33% ownership or >50% voting interest by designated
Russian company(ies)
Morgan Lewis
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