OFAC Issues Guidance to Implement Some Sections of Recently Enacted Russia Sanctions Law
Russian sanctions enacted through legislation signed into law Aug. 2 will take effect starting Jan. 29, said the Office of Foreign Assets Control in guidance released Oct. 31. According to the guidance, the U.S. government will ban the export or…
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re-export of goods or technology in support of exploration or production for deep-water, Arctic offshore or shale projects that have the potential to produce oil in any location, and in which any Russian subject to Executive Order 13662 of March 20, 2014, has either a 33 percent or greater ownership interest or ownership of a majority of the voting interests. Prohibitions that remain imposed include those implemented Sept. 12, 2014, on the export and re-export of goods or technology in support of exploration or production for deep-water, Arctic offshore or shale projects that have the potential to produce oil in Russia, or in Russia-claimed maritime area and extending from its territory, and that involve any Russian person subject to any associated directive, or their property or property interests, the guidance says.