Morgan Lewis US and Russia Sanctions Update
US Sectoral Sanctions - OFAC (cont'd)
Energy
Directive 4 prohibits (as amended/effective Jan. 2018, per CAATSA) without
license
The provision, export or reexport, directly or indirectly, of goods, services (except
financial services) or technology
"in support of exploration or production for deepwater, Arctic offshore, or shale projects that
have the potential to produce oil" in Russia
involving any of these designated entities or their subs (50%-or-more owned)
Gazprom
•
Gazpromneft
•
Lukoil
.
Rosneft
.
Surgutneftegaz
And keep in mind various SSI List amendments to date - singling out several Rosneft,
Gazprom and Surgutneftegaz subs (and again with the same above-noted slide 17
coverage caveats applying)
Note also the 2015 BIS special designation of South Kirinsky field (only part of it is
deep water)... which hasn't yet been expanded to other such "borderline" fields
Morgan Lewis
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