OFAC Implements Expansion of Prohibition on Doing Business With Russian Entities
The Office of Foreign Assets Control has issued an amended directive implementing the provisions of the Countering America’s Adversaries Through Sanctions Act that expanded a prohibition on doing business with certain Russian entities.
In its previously-issued Directive 4, OFAC prohibited the provision, exportation, or reexportation, directly or indirectly, of goods, services (except for financial services), or technology in support of exploration or production for deepwater, Arctic offshore, or shale projects that (a) have the potential to produce oil in Russia or a maritime area claimed by Russia and extending from its territory and (b) involve any person determined to be subject to this directive, including their property or interests in property.
Effective for projects initiated on or after Jan. 29, 2018, OFAC is amending its directive so that this prohibition applies to projects (a) with the potential to produce oil in any location and (b) in which any person determined to be subject to this directive, including their property or interests in property, either has a 33 percent or greater ownership interest in the project or owns a majority of the voting interests in the project.
For more information, please contact Steven Brotherton at (415) 490-1430.