Pursuant to sections 1(a)(i), 1(b), and 8 of Executive Order 13662 of March 20, 2014 “Blocking Property of Additional Persons Contributing to the Situation in Ukraine” (the Order) and

The 14-day debt maturity period applies to debt issued on or after November 28, 2017.As amended and reissued on September 29, 2017, Directive 1 prohibits, within the United States or by U.S. Persons,Naturally, Directive 1 provides that any transaction that “evades or avoids, has the purpose of evading or avoiding, causes a violation of, or attempts to violate any of the prohibitions contained in . The reference to “unintended consequences” may be a first for an OFAC FAQ. [Directive 1] is prohibited . and . On October 31, 2017, U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) revised Directive 4, originally issued in 2014 in connection with Russian deepwater, Arctic offshore, and shale oil exploration and production projects, to expand the scope of the directive as required by Title II of the Countering America's Adversaries Through Sanctions Act (CAATSA). All rights reserved.Critical Resources: Minerals, Rare Earths, Agriculture, WaterOFAC Further Tightens Russia Debt Prohibitions Pursuant to the Countering Russian Influence in Europe and Eurasia Act of 2017 . for or on behalf of,” and “deceptive or structured transaction.” The interpretation of the term “facilitation .

. or on behalf of” is particularly notable. Also pursuant to CAATSA, OFAC is expected to amend and reissue Directive 4 no later than October 31, 2017 (90 days from the date of CAATSA’s enactment). The reference to “unintended consequences” may be a first for an OFAC FAQ.
OFAC originally published Directive 4 in September of 2014, pursuant to Executive Order 13662. OFAC is also required to modify Directive 4 by October 31, 2017. The point of the sectoral sanctions is to impose costs on the Russian Federation for its aggression in Ukraine. However… . As amended on September 29, 2017, Directive 1 now reduces the permissible maturity period of new debt issued on or after November 28, 2017 to 14 days from 30 days.
For US persons engaged in exploration or production on frontier energy projects, newly amended Directive 4 may present significant compliance challenges when it becomes effective in January, and appropriate due diligence will be warranted.

. The point of the sectoral sanctions is to impose costs on the Russian Federation for its aggression in Ukraine. Copyright © 2020 MassPoint Legal and Strategy Advisory PLLC.

. Steptoe has more than 500 lawyers and other professional staff across offices in Beijing, Brussels, Chicago, Hong Kong, London, Los Angeles, New York, San Francisco, and Washington.

Specifically, that executive order provides that the Secretary of the Treasury may designate any person determined “to operate in such sectors of the Russian Federation economy as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State, such as financial services, energy, metals and mining, engineering, and defense and related materiel.” Section 223(a) of CRIEEA/CAATSA essentially reiterates that the Treasury Department may target any sector of the Russian economy it sees fit, including the railway and metals and mining sectors. As required by the Countering Russian Influence in Europe and Eurasia Act of 2017 (CRIEEA), the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) on September 29, 2017 amended and reissued OFAC Directive 1 (Directive 1).As amended, Directive 1 continues to prohibit certain “new” debt, equity, and related transactions involving entities subject to U.S. On October 31, 2017, the Office of Foreign Assets Control (OFAC) took a number of actions to implement the Countering Russian Influence in Europe and Eurasia Act (CRIEEA) (also known as the Countering America’s Adversaries Through Sanctions Act (CAATSA), a larger sanctions statute of which CRIEEA was a part). Subsection 1 prohibits US persons from providing goods, services (except financial services), or technology in support of projects The main takeaway is that while both restrictions are significant, projects in Russia are particularly risky.The Steptoe International Compliance blog offers a fresh take on the issues that arise in the world of international regulatory enforcement and compliance, with a focus on the dynamic fields of export controls, economic sanctions, anti-corruption, and ‎more.In more than 100 years of practice, Steptoe has earned an international reputation for vigorous representation of clients before governmental agencies, successful advocacy in litigation and arbitration, and creative and practical advice in structuring business transactions. Today is the effective date of the expanded sanctions set out in The new restrictions are applicable to projects “initiated” on or after today, January 29. The amendment implemented Section 223 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), signed into law by President Trump last …


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