On January 28, 2019, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) designated Petróleos de Venezuela, S.A. (“PdVSA”) as a Specially Designated National (“SDN”) under Executive Order 13850 of November 1, 2018 because it operates in the Venezuelan oil sector. As a result, US Persons (i.e., entities organized under US laws and their non-US branches; individuals and entities physically located in the United States; and US citizens and permanent resident aliens (“Green Card” holders) wherever located or employed) are prohibited, in the absence of an OFAC license, from transacting, directly or indirectly, with PdVSA and any entities owned 50% or more by PdVSA (“PdVSA Subs”). In addition, except as permitted under OFAC licenses, US Persons are required to block property or property interests of PdVSA/PdVSA Subs that are currently in the United States, come within the United States or the possession or control of any US Person.Read more…
On 29 December 2018, the Russian Prime Minister signed Resolution No. 1716-83 implementing an import ban with respect to the Ukrainian goods. The import ban was introduced within the framework of the Russian countersanctions against Ukraine adopted under Presidential Decree No. 592 dated 22 October 2018.
The list of goods affected by the measure include agricultural products, raw materials, food products, industrial goods and certain personal hygiene products listed according to their names and HS classification codes.
Per Resolution No. 1716-83 such goods are prohibited from entering Russia if they (i) originate from Ukraine, (ii) are supplied from Ukraine, or (iii) have been in transit through the territory of Ukraine.
The import ban does not apply to those goods which will be transited through Russia to third countries (subject to certain conditions, such as if the goods will be transited under the Russian customs convoy regime).
Resolution No. 1716-83 entered into force immediately upon signing.
On December 19, 2018, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) submitted a letter to congressional leaders (“Congressional Letter”) notifying Congress of its intent to terminate the sanctions imposed on En+ Group plc (“En+”), UC Rusal plc (“RUSAL”), and JSC EuroSibEnergo (“ESE”) in 30 days. On the same day, OFAC announced new sanctions against a number of individuals and entities for their involvement in a range of malign activities. Concurrently, the US Department of State announced it had added 12 individuals and entities to the List of Specified Persons under Section 231 of the Countering America’s Adversaries Through Sanctions Act (“CAATSA”) for being part of, or operating for or on behalf of, the defense or intelligence sector of the Russian Federation.Read more…
On 25 December 2018, the Russian Prime Minister signed Resolution No. 1656, which expands the list of Ukrainian individuals and legal entities subject to Russian sanctions.
The sanctions against Ukraine were initially introduced by the Russian Government on 1 November 2018 under Resolution No. 1300. The sanctions include: (a) the blocking/ freezing of non-cash funds, non-documentary securities and property located within the Russian Federation, and (b) a ban on the transfer of money from Russia abroad.
Resolution No. 1656 adds 245 individuals and 7 companies to this list. As a result, the current list includes 567 individuals and 75 companies from Ukraine.
Resolution No. 1656 entered into force on 25 December 2018.