In its FAQ guidance accompanying the amended Directive, OFAC provided definitions for “deepwater projects,” “shale projects,” “Arctic offshore projects,” and the term “production.” It also provides examples of activities prohibited under Directive 4, which include drilling services, geophysical services, geological services, logistical services, management services, modeling capabilities, and mapping technologies. Directive 4 does not apply to gas-only projects. OFAC also provided guidance regarding CRIEEA’s authorization of sanctions targeting the railway and metal and mining sectors.Įxpansion of Prohibitions on Supplying Russian Oil Projectsĭirective 4 as amended prohibits US persons from directly or indirectly providing, exporting, or re-exporting goods, services (except for financial services), or technology in support of exploration or production for deepwater, Arctic offshore, or shale projects that meet all three of the following criteria: (1) the project was initiated on or after Janu(2) the project has the potential to produce oil in any location and (3) Russian individuals or entities designated under Directive 4-individually or in the aggregate-either have a 33 percent or greater ownership interest in the project or own a majority of the voting interests in the project. As part of this, OFAC amended Directive 4 under Executive Order 13662-related to prohibitions on supplying Russian oil projects-and issued updated Frequently Asked Question (FAQ) guidance on restrictions related to foreign financial institutions, facilitating transactions with sanctioned persons, sanctions evasion, and investments in Russian state-owned assets. 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).
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