ofac directive 2Blog

ofac directive 2

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 31 C.F.R.

OFAC also sanctioned Didier Casimiro, Rosneft Trading’s Chairman and President, who a State Department For current business partners of Rosneft Trading, OFAC has issued The pre-existing “SSI List” restrictions on Rosneft Trading remain in place during and after the wind-down period, prohibiting transactions or dealings in its “new debt” of longer than 60 days maturity (under OFAC 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.

CRIEEA also directs OFAC to revise Directive 4 on or before October 31, 2017.

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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.. 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.

The restrictions in Directive 2 also apply to entities that are owned 50% or more by SSI- Listed persons, or entities that OFAC determines to be "controlled" by a SSI-Listed person. We look to highlight movements across the spectrum of policy areas in the coming year.Dentons is home to top-tier talent that is found at the intersection of geography, industry knowledge and substantive legal experience. Dentons, the world’s largest law firm, has launched a new Market Insights publication entitled “Digital Transformation and the Digital Consumer”, which examines the legal implications of the online economy.Global law firm Dentons earned 109 individual and 43 practice rankings - a 20% increase over last year - in the most recent edition of On September 29, 2017, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) amended and re-issued Ukraine-/Russia-related sanctions Directives 1 and 2. DIRECTIVE 2 (AS AMENDED) 1. Accordingly, the relevant tenors of prohibited “new debt” under Directive 2 are as follows:Ryan Fayhee is a partner in Washington, D.C. Mr. Fayhee previously was with the United States Department of Justice for 11 years, where he was a leading national security prosecutor in the areas of economic espionage, export controls, sanctions enforcement, and cybercrime.

DIRECTIVE 2 (AS AMENDED ON SEPTEMBER 29, 2017) 1. The restrictions in Directive 2 also apply to entities that are owned 50% or more by SSI- Listed persons, or entities that OFAC determines to be "controlled" by a SSI-Listed person. On September 29, 2017, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) amended and reissued Beginning on November 28, 2017, Directive 1 will prohibit US Persons from:Prior versions of Directive 1 are superseded by the September 29, 2017 version of Directive 1. 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. 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."

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