International Sanctions and the Energy Sector – Part 2: Russia. Russian banks now subject to … U.S. persons are restricted from engaging in specific transactions with these entities. Sectoral sanctions have not been modified since their adoption in 2014, and despite a push for their expansion from some EU member states – namely Poland and Baltic States – other member states – Italy, Austria, Greece, Cyprus and Hungary – … The Russian sectoral sanctions were multi-lateral sanctions, imposed by … This likely reflects the types of projects being progressed in Russia since the sanctions came into force. Haverly paid roughly $75,000 for two violations of the Ukraine-Russia Sectoral Sanctions (SSI). EU operators are prohibited from making funds available to those sanctioned. In response to the annexation of Crimea by the Russian Federation, some governments and international organisations, led by the United States and European Union, imposed sanctions on Russian individuals and businesses. The United States Treasury and Commerce Departments have announced similarly broad expansions of US sectoral sanctions and export controls on Russia. The European Union has once again extended economic sectoral sanctions against Russia for six more months, the EU Council said in a statement … OFAC also designated as Specially Designated Nationals (SDNs) several other individuals and entities, including Kalashnikov Concern, manufacturer of the AK-47 … In addition, the United States has imposed sanctions on Russia in response to human Sectoral Sanctions on Energy 2 Russia’s Approach to Dealing with Sanctions 3 Impact on Russia’s Energy Sector 4 Major Oilfield Services Players in Russia 6 Uneven Application of Sanctions 7 Russia’s Impressive Growth in Oil Production 8 Energy Success Fuels Geopolitical Momentum 8 Implications 10 About the Author 12 OFAC publishes a list to identify persons operating in sectors of the Russian economy identified by the Secretary of the Treasury pursuant to Executive Order 13662. EU Policy & Regulatory Update: EU prolongs sectoral sanctions on Russia. Monday, August 4, 2014. On July 16, 2014, the US Treasury Department, Office of Foreign Assets Controls (OFAC) issued the Sectoral Sanctions Identifications List (SSI List), imposing sanctions on several entities in the Russian financial and energy sectors. The difference between these parties is that the first two are operating in Russia’s financial sector, while the other two are operating in Russia’s energy sector. 10/*9 1: ;&. In 2014 the US, EU and other states imposed a range of sanctions on Russian companies and individuals in connection with the annexation of the Crimea and Russia's involvement in a military conflict in Eastern Ukraine. Sanctioned individuals cannot travel to the EU. Mostly, however, energy companies have been able to progress their projects unimpeded by the sanctions. Currently, the bank is on the US Department of Treasury’s Sectoral Sanctions Identifications (SSI) List and on the EU sanctions list, which restricts Sberbank’s access to the EU and US capital markets, but doesn’t include blocking the bank’s foreign assets. • Russia has also enacted an SDN-like sanctions act on 1 Nov. 2018, with specific designations, against Ukraine and further expanded it on 25 Dec. 2018 ( link) • Increasing reports of Russian companies (including oil producers) trying to move away from The Treasury Department’s Office of Foreign Asset Control (OFAC”) continues its enforcement run. Russian Prime Minister Mikhail Mishustin thinks that Russia and China teaming up for joint development is the best response to the unfriendly … An OFAC official described the new sectoral sanction as “…narrow prohibitions, incredibly hard and complicated to apply [5] …”. The United States added Rosneft and other Russian entities to its “Sectoral Sanctions Identifications List” (SSI List) in 2014 over Russia’s role in the Ukraine crisis. Share this; ... (CFSP) 2019/1108, extending the economic sanctions on Russia in response to Russia's actions destabilising the situation in Ukraine until 31 January 2020. On April 15, 2021, the White House and the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a package of economic sanctions targeting Russia, including expansive new legal authorities that would allow for the imposition of additional future sanctions on Russia in the technology sector and on Russian government bodies. Sanctions are a long game by default, so CAATSA is still settling in, and its main custodian, the US Office of Foreign Assets Control (OFAC), is far from establishing the full practice – and limits – of its implementation. These sanctions prohibit certain categories of dealings involving U.S. persons of the existing blacklist (SDN) and sectoral (SSI) sanctions enacted by the series of Executive Orders since 2014 against Russia which will make it harder for President Trump (and his successors) to narrow or otherwise loosen any of these sanctions by executive action – and would require new

Sectoral sanctions apply to specific entities in Russia’s financial, energy and defense sectors. CFR ; Table of Popular Names ... oil or gas in Russian deepwater (greater than 500 feet) or Arctic offshore locations or shale formations in Russia, or are unable to determine whether the item will be used in such projects. In Russia, on the other hand, GDP growth has decreased since the imposition of sanctions, contracting by 2.8 percent in 2015.

Obama's comments affirmed that barring a full-on military incursion, Russia is unlikely to face those beefed-up sanctions, which could ricochet and harm U.S. allies in Europe that do business with Russia.

In particular, tests for ownership and control may be more stringent. As a result, the following sanctions will be imposed (full or partial waivers are noted below) after the 15-day Congressional notification period: Foreign Assistance:Termination of assistance to Russia under the Foreign Assistance Act of 1961, except for urgent humanitarian assistance and food or other agricultural commodities or products. U.S., EU Expand Russia Sanctions and Export Controls Continued 2 new equity of the banks subject to Directive 1 by U.S. persons or within the United States. This likely reflects the types of projects being progressed in Russia since the sanctions came into force. Russian Prime Minister Mikhail Mishustin thinks that Russia and China teaming up for joint development is the best response to the unfriendly … The EU has adopted Council Decision (CFSP) 2020/2143, which renews the sectoral sanctions against Russia until 31 July 2021. Economic sanctions are a withdrawal of financial and trade partnerships levied against governments to punish them for violating international norms, such as what Russia did by invading sovereign Ukraine without provocation. Directives found within the list describe prohibitions on dealings … As with the prior round of sanctions at the end of July, many of the new US and EU measures are similar and fairly well coordinated. Germany and France launched a number of diplomatic initiatives targeted at implementing a cease- fire and resolving areas of conflict between Ukraine and Russia. § 746.5 Russian industry sector sanctions.

The US and EU economic sanctions against Russia, as further tightened in Sept. 2014 and fairly well coordinated with one another, have basically remained as is since then. The financial sanctions targets are also listed in the UK's Consolidated List of Financial Sanctions Targets. OFAC also added Sberbank, Russia’s largest bank, to the Sectoral Sanctions Identification List (SSIL). Sectoral sanctions have not been modified since their adoption in 2014, and despite a push for their expansion from some EU member states – namely Poland and Baltic States – other member states – Italy, Austria, Greece, Cyprus and Hungary – … The majority of the sanctions by the European Union and the United States imposed on Russia as of May 21, 2021 targeted companies the fuel and energy sector. • … Sectoral sanctions. OFAC Imposes First Penalty for Russia Sectoral Sanctions Violations. Regulations (“EAR”) to include the “Russian Industry Sector Sanctions” as section 746.5.

Russian embargo of Ukrainian goods is trade and economic confrontation that resulted from putting all Ukrainian importers to the "list of risk" by the Federal Customs Service of Russia on 14 August 2013 that resulted the embargo of imports from Ukraine to Russia. The US has issued wide ranging financial and trade sanctions since 2014 in respect of Russia in connection with actions which undermine the sovereignty of Ukraine. Secondary sanctions have existed in the Russia sanctions context since 2014. In coordination with the EU, the Obama Administration expanded sectoral sanctions in … For Novatek and Rosneft, the sectoral sanctions prohibit U.S. persons from lending to these entities when the debt matures after 90 days. EU operators are prohibited from making funds available to those sanctioned. The Sectoral Sanctions Identifications List includes persons determined by OFAC to be operating in sectors of the Russian economy identified by the Secretary of the Treasury pursuant to Executive Order … Recent sanctions against Russia, including CAATSA and the April 6, 2018 “oligarch sanctions” were imposed by the United States unilaterally. CAATSA mandates secondary sanctions, making European companies, which have much more exposure to Russia, susceptible to penalties from U.S. regulators. U.S. persons are restricted from engaging in specific transactions The measures were originally introduced in 2014 in view of Russia’s destabilising actions against Ukraine. WASHINGTON – Due to continued Russian efforts to destabilize eastern Ukraine, Treasury Secretary Jacob J. Lew today determined that persons operating within Russia’s defense and related materiel sector may now be subject to targeted sanctions under Executive Order 13662. The financial sanctions targets are also listed in the UK's Consolidated List of Financial Sanctions Targets. The Ukraine-related sanctions program was the first of its kind to have sectoral sanctions and it specifically targeted Russia’s financial and energy sectors. A sanctions licence is not required for imports of non-military goods covered by the Regulations from an EU Member State which originate in or … + & 1/:099*:0/ &$,.32,3- H,--, "25,. Sanctions related to Russia were imposed under the Special Economic Measures Act in order to respond to the gravity of Russia’s violation of the Ukraine imposes its first-ever sectoral sanctions.

US sanctions. rather than as an escalation of sanctions against Russia, adds one more impediment to the framework of U.S. restrictions targeting the Russian energy sector, which has grown steadily since the U.S. government first initiated sanctions against Russia last year in connection with developments in … Sign up for SSI List e-mail updates.

and EU Ukraine- Related Sanctions Compared,” below). The decision was reached because the Minsk agreements have not yet been fully implemented by Russia. Overall, three types of sanctions were imposed: Yesterday evening the European Council issued Council Regulation No. 2.

Apr.16.2021. In its statement the Council sums up the scope of sanctions imposed by Council Regulation 692/2014 and Council Decision 2014/386/CFSP. Apart from applying to the people and entities responsible, the sanctions included sectoral sanctions on finance, oil technology, and defense technology. The sanctions lists have increased each year and now consist of … In a recent case against Haverly Systems, Inc., OFAC sent an important reminder to US companies about compliance with the Ukraine-Russia Sectoral Sanctions Program. Restrictions apply to new equity investment and financing for entities in Russia’s financial sector; and new financing for identified entities in Russia’s energy and defense sectors. While it is harder to causally link the impact of sanctions with Russia’s decline in economic growth, it appears the decrease in trade … US sanctions. The EU has extended its sectoral sanctions against Russia until 31July 2017. The sanctions include: EU based assets of those sanctioned are frozen. Sanctions imposed on Russia’s oil sector generally target longer-term oil production and to date have not reduced Russian oil supply or trade. This rule states that if any of these entities that are sanctioned, which are the government of Venezuela and the PdVSA, has a company and owns 50 percent or more of that company, that company is also sanctioned under this executive order. The order, described by Secretary of the Treasury Janet Yellen as “a sweeping new authority to confront Russia’s continued and growing malign behavior,” authorizes sanctions to Subscribe to the OFAC RSS feed (includes notices of SSI List updates). Oil production in Russia has increased since oil-sector sanctions began in 2014, although the country has arguably incurred economic costs in order to incentivize and support oil output levels. Second round of CBW Act sanctions (mandated by that Act, given Russia’s failure to satisfy the Act’s conditions following imposition of the March first-round – see slide 64) o denial of new or pending permit applications to ATF for permanent importation of firearms and ammunition, as U.S. Imposes Sectoral Sanctions Against Russia; Targets Banking, Energy and Arms, But Scope Is Limited Continued 3 The following two entities and one individual were designated as SDNs for threatening the peace, security, stability, sovereignty, or territorial integrity of Ukraine: Luhansk People’s Republic Donetsk People’s Republic not identical to corresponding EU sanctions. Most sectoral sanctions require abiding by the 50 percent rule. The reason for the bank’s covert tactics in Crimea is Sberbank management’s hope to avoid harsher Western sanctions. The sectoral sanctions on Russia’s central bank, sovereign wealth fund, and finance ministry are further circumscribed in several key respects. Sanctioned individuals cannot travel to the EU. sectoral sanctions against Russia. Unlike a violation of “primary sanctions,” such as the sectoral sanctions discussed above (which can result in civil or criminal penalties), a party that engages in conduct that is subject to secondary sanctions can be sanctioned by the U.S. government. Sectoral sanctions are not blocking sanctions. Last year, the United Stated imposed sanctions citing CAATSA on Nato-ally Turkey for acquiring S-400 missiles from Russia. The sanctions frameworks are complex, changing, and, at … These new sanctions, issued pursuant to Exec.Order 13662 (pdf), are different than the existing Ukraine-related sanctions.

Obama suggested that if Russia disrupts Ukraine May 25 elections the sectoral sanctions against Moscow would be inevitable and could hit the Russians arms and financial sector.

Specifically, OFAC has issued the Sectoral Sanctions Identifications List (SSI List). The difference between these parties is that the first two are operating in Russia’s financial sector, while the other two are operating in Russia’s energy sector. Sectoral Sanctions The most novel of the Russia/Ukraine-related sanctions are the “sectoral” sanctions.20 The sectoral sanctions were designed to imp ose a “targeted” impact on the Russian economy, as compared to more traditional OFAC sanctions. European Union Issues New Sectoral Sanctions Against Russia. The Ukraine-related sanctions program was the first of its kind to have sectoral sanctions and it specifically targeted Russia’s financial and energy sectors. The Ukraine/Russia sanctions program, including the sectoral sanctions implemented via the Directives, governs US persons 1 and any conduct that takes place within the United States. Sectoral Sanctions Identifications (SSI) List.

The cornerstone of the US’s sanctions against Russia, the Countering America’s Adversaries Through Sanctions Act (CAATSA), had its first anniversary on 2 August. Sectoral sanctions in relation to the financial services, energy and defense and related material sectors, in respect of which a sanctions list called the Sectoral Sanctions Identification Lists (SSIL) has been created and updated over time. This paper focuses on the financial sanctions that have had the dominant macroeconomic impact, keeping financial resources out … U.S. persons are restricted from engaging in specific transactions with these entities. President Biden Imposes Additional Sanctions on Russia. These sectoral sanctions would be tailored to address particular areas of Russian trade vulnerability, Assistant Secretary of State Victoria Nuland told the House Foreign Affairs Committee. On July 16, 2014 the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) ramped up its Ukraine-related sanctions program against Russia. 1.3. Sectoral Sanctions Identifications (SSI) List. The European Union first imposed the sectoral sanctions against Russia on 31 July 2014 in connection with Russia’s perceived actions in the conflict in Ukraine. As with the prior round of sanctions at the end of July, many of the new US and EU measures are similar and fairly well coordinated. The US took the lead early to advocate for sectoral sanctions, while the UK also strongly condemned Russia and publicly argued in favor of further measures. So far, the U.S. has slapped sanctions on individuals but hasn't targeted entire economic sectors, such as Russia's critical energy sector. Wednesday, November 14, 2018. Last Updated: 03/12/2020. July 17, 2014. 15 CFR § 746.5 - Russian industry sector sanctions. In September 2014, the sanctions were extended to include the financial, energy and defence sectors, as well as the importation and exportation of dual-use goods. Most Russia-related sanctions have been in response to Russia’s 2014 invasion of Ukraine. This sanctions regime is aimed at encouraging Russia to cease actions destabilising Ukraine or undermining or threatening the territorial integrity, sovereignty or … This is an update to Schulte Roth & Zabel’s July 30, 2014 Client Alert titled “Threatened Sectoral Sanctions Against Russia Become Reality.” On Sept. 12, 2014, the United States and European Union (“EU”) implemented increased Ukraine-related sanctions against the Russian Federation (“Russia”). In addition, they prohibit U.S. business, trade, or investment in occupied Crimea. The sanctions include: EU based assets of those sanctioned are frozen. In response to opening the consulate of the Republic of Nicaragua in the temporarily occupied Crimea, on 2 February 2021 the Parliament of Ukraine for the first time in its history approved sectoral sanctions against the Republic of Nicaragua (“Sectoral Sanctions”). These sanctions impose a license requirement for the export to Russia of certain items if the exporter, reexporter, or transferor knows that the item “will be used directly or indirectly in exploration for, or production of, oil or The EU and US sectoral sanctions target oil exploration and production from deepwater, Arctic offshore or shale projects in Russia. The United States Treasury and Commerce Departments have announced similarly broad expansions of US sectoral sanctions and export controls on Russia. sector, other key sectors of the Russian economy, or occupied Crimea. Thus, sectoral sanctions do not prohibit U.S. persons doing business with SSIL listed parties like Rosneft. Target 185 people 48 entities responsible for undermining Ukraine’s territorial integrity, sovereignty and independence. Sectoral sanctions apply to specific entities in Russia’s financial, energy and defense sectors. Restrictions on exports to Russia of oil and gas-related goods and technologies, and especially for the Arctic oil exploration and production, deep water oil exploration and production and shale oil projects; Financial institutions should review their due diligence procedures and operational policies in light of the UK SIs. Time has since borne out that the Russian sectoral sanctions were successful. This is an update to Schulte Roth & Zabel’s July 30, 2014 Client Alert titled “Threatened Sectoral Sanctions Against Russia Become Reality.” On Sept. 12, 2014, the United States and European Union (“EU”) implemented increased Ukraine-related sanctions against the Russian Federation (“Russia”). In particular, the package argues for the relief of sanctions targeting North Korea’s civilian sector, according to … The MH17 tragedy helped galvanize EU support for sectoral sanctions on Russia similar to those the United States had imposed (for more, see “U.S. U.S. Sanctions on Russia Sanctions are considered by many to be a central element of U.S. policy to counter Russian malign behavior. On April 15, 2021, the White House and the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a package of economic sanctions targeting Russia, including expansive new legal authorities that would allow for the imposition of additional future sanctions on Russia in the technology sector and on Russian government bodies. This type of sanctions applies to companies and individuals in Russia’s financial, energy, and defense sectors. On October 31, 2017, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) amended and reissued Directive 4 of the Ukraine/Russia-related sectoral sanctions (“Directive 4”), which targets the Russian energy sector, and updated its guidance regarding the implementation of Ukraine/Russia-related sanctions. Target 185 people 48 entities responsible for undermining Ukraine’s territorial integrity, sovereignty and independence. 13662, prohibiting U.S. persons (wherever they are located) and persons within the United States from providing new financing to persons on the new SSI List, which currently applies to two critical sectors of the Russian economy: (1) On September 29, 2017, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) amended and reissued Directive 1 and Directive 2 implementing US sectoral sanctions targeting Russia pursuant to the Countering America’s Adversaries Through Sanctions Act (“CAATSA”). As part of this new approach, on July 16, 2014, OFAC issued Directives 1 and 2 pursuant to E.O. International Sanctions and the Energy Sector – Part 2: Russia. In the case of Russia-related sanctions, sectoral sanctions have a narrower meaning; they apply to specific entities in Russia’s financial, energy, and defense sectors that OFAC has identified for inclusion on the Sectoral Sanctions Identifications (SSI) List. The sale of goods and services, licensing of software, or other trade or business transactions are not prohibited by sectoral sanctions at the present time. Russia has maintained a ban on the importation of nearly all U.S. as well as most European food products since August 2014 in response to Ukraine-related sanctions. For Novatek and Rosneft, the sectoral sanctions prohibit U.S. persons from lending to these entities when the debt matures after 90 days. First, they do not become effective until 60 days after the issuance of the Directive. The suggested sanctions relief largely mirror China and Russia’s Dec. 2019 proposals, which the two countries never officially submitted to the UNSC due to U.S. disinterest, sources said. They target the financial, energy, and defence … The EU and US sectoral sanctions target oil exploration and production from deepwater, Arctic offshore or shale projects in Russia. The US has issued wide ranging financial and trade sanctions since 2014 in respect of Russia in connection with actions which undermine the sovereignty of Ukraine. Mostly, however, energy companies have been able to progress their projects unimpeded by the sanctions. As the unrest expanded into other parts of Eastern Ukraine, and later escalated into the ongoing war in the Donbass region, the scope of the sanctions increased. Specific types of transactions, such as financial and energy-related transactions, are prohibited for US persons and, like the Venezuelan sanctions, the OFAC 50 percent rule is strictly enforced in the context of the Ukraine-related sectoral …

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