ofac directive 2

As amended on September 29, 2017, Directive 2 now reduces the permissible maturity period of new debt issued on or after November 28, 2017 to 60 days from 90 days. The Trump administration has made clear that it intends to impose significant pressure on the Maduro regime in Venezuela, and these moves show that some collateral damage may be viewed as acceptable in getting to that goal. 13850, provided that such wind-down activity is:  (i) consistent with General License 36; and (ii) completed prior to 12:01 a.m. eastern daylight time, May 20, 2020. Thus, although the US does not maintain a general commercial embargo on Russia (as compared to, for example, Cuba, Iran, North Korea and Syria), the scope of what the US does prohibit or restrict regarding Russia has continued to expand significantly. For more information, visit US Sanctions Rosneft Subsidiary and a Rosneft Director and Vice President for Venezuela Oil TradeThree Key Takeaways from OFAC’s Latest Venezuela Sanctions ActionsUPDATE: US Sanctions Second Rosneft Subsidiary for Venezuela Oil TradeNew Round of Sanctions Block Government of Venezuela, Issue General LicensesVenezuela Challenge to US Sanctions Escalates at WTO Unsolicited emails and other information sent to Dentons will not be considered confidential, may be disclosed to others, may not receive a response, and do not create a lawyer-client relationship. Non-U.S. persons unable to wind down activities with Rosneft Trading S.A. before 12:01 a.m. eastern daylight time, May 20, 2020, may seek guidance from OFAC.”  This statement indicates that any other types of business with Rosneft Trading, including any new business by non-US persons, will create potential US sanctions risk.How this develops will be shaped in part by how Rosneft Trading (and potentially other Russian organizations including Rosneft itself) recalibrate their business with Venezuela and whether they are able to reach an understanding with the US government that may allow for a decrease in tensions, and potentially the removal of Rosneft Trading and/or Mr. Casimiro from the SDN list. If you need oversight of the latest local government announcements or a comparison guide to the regulations that apply to your employees across markets, we are here to help you.There is no new normal for any organization for the foreseeable future. The revised version of Directive 4 will extend the restrictions on the provision of goods or services related to oil exploration and production to include any new deep-water, Arctic offshore or shale projects that have the potential to produce oil anywhere in the world in which a SSI-designated entity has a "controlling interest" or a "substantial non-controlling ownership interest." Entering into new business involving Rosneft Trading S.A. will not be considered wind-down activity. UNDER EXECUTIVE ORDER 13662 . Dentons is a global legal practice providing client services worldwide through its member firms and affiliates. DIRECTIVE 2 (AS AMENDED) 1. The amended and reissued Directives 1 and 2 will become effective November 28, 2017, in accordance with CAATSA. under Directive 1 and on transacting in, providing financing for, or otherwise dealing in debt with a maturity of longer than 90 days issued on or after July 16, 2014 by, on behalf of, or for the benefit of the persons identified under Directive 2. As amended on September 29, 2017, Directive 2 now reduces the permissible maturity period of new debt issued on or after November 28, 2017 to 60 days from 90 days. The Office of Foreign Assets Control (OFAC) is a financial intelligence and enforcement agency of the U.S. Treasury Department.It administers and enforces economic and trade sanctions in support of U.S. national security and foreign policy objectives. The Treasury Orders and Directives contained on this website show Administrative Edits, to reflect (misspelled words, reorganizing or technical changes, (updates of legal citations, new editions of forms, links to selected web sites, etc. As required by the Countering Russian Influence in Europe and Eurasia Act of 2017 (CRIEEA), on September 29, 2017, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC), amended Directives 1 and 2 issued under Executive Order 13662, which imposed sanctions on the Russian financial and energy sectors..

The amended Directives phase in these reductions, with full implementation for debt issued on or after November 28, 2017.The revised Directives further expand the restrictions the US imposes against Russia, even though the Directives do not entirely prohibit all transactions and dealings. Rosneft and its affiliates were originally designated on the SSI List in the original Directive 2 issued on July 16, 2014, and in Directive 4 on September 12, 2014. Working with Dentons, you will have the opportunity to learn from the best lawyers in the industry at the largest law firm in the world.

This is another example of OFAC targeting a subsidiary of a major global company, while clarifying through guidance that the sanctions do not apply to the parent company directly.