US Sectoral Sanctions
US Sectoral Sanctions - OFAC (cont'd)
Energy (cont'd)
Note OFAC FAQ 413 (and similar BIS) clarification that "deepwater" = over 500 ft.
And OFAC FAQ 418 (and similar BIS)
-
Clarification that “shale project” doesn't include E&P through shale to locate or extract
oil in reservoirs
Also, apparently, not all hard-to-extract = shale (not addressed further in later FAQ
updates)
And OFAC FAQ 421
-
Re "Arctic offshore" = offshore field north of Arctic Circle
Including an Oct. 2017 clarification that this bar doesn't cover horizontal drilling
operations originating onshore that extend to seabed areas above Arctic Circle
And OFAC FAQ 420 - re only production (and not midstream / downstream)
activities are covered
Morgan Lewis
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