The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed additional sanctions targeting Russia’s energy sector under E.O. 14024.
OFAC designated Open Joint Stock Company Rosneft Oil Company (Rosneft) and Lukoil OAO (Lukoil), and designated a number of Russia-based subsidiaries.
According to the announcement, all property and interests in property of designated or otherwise blocked persons that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. Any entities owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked. Unless authorized by a general or specific license or exempt, U.S. persons are generally prohibited from transactions involving such property or interests in property.
OFAC highlighted potential civil or criminal penalties for violations and secondary-sanctions risk for foreign financial institutions that conduct or facilitate significant transactions, including persons blocked pursuant to E.O. 14024.
OFAC issued Russia-related General License 124A (“Authorizing Petroleum Services and Other Transactions Related to the Caspian Pipeline Consortium and Tengizchevroil Projects”), General License 126 (“Authorizing the Wind Down of Transactions Involving Rosneft or Lukoil”), General License 127 (“Authorizing Certain Transactions Related to Debt or Equity of, or Derivative Contracts Involving, Rosneft or Lukoil”), and General License 128 (“Authorizing Certain Transactions Involving Lukoil Retail Service Stations Located Outside of Russia”).
OFAC also updated the Specially Designated Nationals and Blocked Persons List and made changes to Sectoral Sanctions Identifications List entries.
