US Sectoral Sanctions
EU Sectoral Sanctions (cont'd)
Energy (cont'd)
Also, provision of the following services related to any Annex II items needs
authorization from national competent authority (per art. 4.3 - existing since
the initial July 2014 version of the Reg., and as refined by the Dec. 2014
amendment):
Technical assistance (or brokering services) re Annex II items and re provision,
manufacture, maintenance and use of those items directly or indirectly
to anyone in Russia (including its EEZ and Shelf)
or to anyone in any other country if concerns items for use in Russia (including EEZ / Shelf)
Financing or financial assistance re Annex II items - including grants, loans and export
credit insurance
for any sale, supply, transfer or export of those items
or for any provision of related technical assistance
also (as above for technical assistance) directly or indirectly to anyone in Russia (including its
EEZ / Shelf) or to anyone in another country for use in Russia (including its EEZ / Shelf)
Per art. 4.4, authorizations may be granted on same basis as set out in art. 3 (and
possible emergency services, with prompt post-reporting - per arts. 4.3 and 3.5)
Morgan Lewis
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