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. OFAC’s amendment and reissuance of Directive 4 was expected pursuant to Section 223(d) of Title II of the Countering America’s Adversaries Through Sanctions Act (“CAATSA” see our previous blog post on CAATSA here). Also under CAATSA, Directive 1 and Directive 2 were amended and reissued on September 29, 2017 (see our previous blog post here). OFAC originally published Directive 4 in September of 2014, pursuant to Executive Order 13662. In conjunction with OFAC’s guidance, the US Department of State (“State Department”) also published guidance regarding CAATSA Sections 225 and 232.