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.