On February 23, 2022, as “another piece of [the US government’s] initial tranche of sanctions in response to Russia’s actions in Ukraine,” the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) designated Nord Stream 2 AG, the Swiss company in charge of building Russia’s Nord Stream 2 gas pipeline, and its German chief executive officer, Matthias Warnig, to OFAC’s List of Specially Designated Nationals and Blocked Persons. The sanctions on Nord Stream 2 follow the comprehensive sanctions imposed on the “so-called Donetsk People’s Republic (DNR) and Luhansk People’s Republic in Ukraine (LNR)” on February 21, 2022, and financial sanctions imposed on Russia on February 22, 2022, as reported on our blog here and here respectively. The White House issued this statement on the Nord Stream 2 sanctions.
Concurrently with the issuance of the sanctions described above, OFAC issued a Russia-related General License 4 (“GL 4”), “Authorizing the Wind Down of Transactions Involving Nord Stream 2 AG.” GL 4 allows wind-down transactions involving Nord Stream 2 AG through 12:01 a.m. eastern standard time, March 2, 2022.
Baker McKenzie will continue closely monitoring developments related to the Russia-Ukraine situation and will update this blog accordingly.
Author
Bart M. McMillan
Mr. McMillan's practice involves compliance counseling; compliance programs; licensing; compliance reviews; internal investigations; voluntary disclosures; administrative enforcement actions; criminal investigations; customs inquiries, audits, detentions, and seizures; and trade-compliance due diligence and post-acquisition integration in mergers and acquisitions. His practice includes matters that implicate the US International Traffic in Arms Regulations (ITAR), US Export Administration Regulations (EAR), US National Industrial Security Program (NISP), the US Committee on Foreign Investment in the United States (CFIUS), and equivalent non-US laws. Mr. McMillan regularly advises on and represents clients in matters involving technology, including its control, protection, accidental disclosure, diversion, or unauthorized collection.
Mr. McMillan has extensive experience working with companies in the aerospace and defense industry, as well as companies in the Middle East and other parts of Asia.
Author
Vivian Tse
Vivian advises clients on a wide range of international trade issues, including US export controls such as the Export Administration Regulations (EAR), sanctions, internal investigations, and voluntary disclosure filings to the US government. She also advises clients on M&A export control, sanctions, and customs and import law due diligence reviews of target companies, in collaboration with the Firm’s M&A team in multiple jurisdictions. Further, Vivian’s practice covers multijurisdictional commercial transactions including contract localizations and post-acquisition integrations.
