US Sectoral Sanctions
US Sectoral Sanctions - OFAC (cont'd)
Energy (cont'd)
The Directive 4 export ban thus covers essentially
-
All US-origin goods, US-origin services (except for financial services - covered in
Directive 2), tech. assistance and technology in respect of such projects
To the five main listed companies and their subs (and expressly including the added
named Rosneft, Gazprom and Surgutneftegaz subs)
And likely also to / for use at the South Kirinsky field (and any others that may be so
designated)
The carve-out for financial services (includes clearing transactions and providing
insurance re such activities - per OFAC FAQ 412 - but see also the further explanation
in FAQ 415)
There have been some license applications / favorable actions under Directive 4
(but still a much stricter approach than in the EU to date)
Note the "support services" compliance focus / risk
Morgan Lewis
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