OFAC Publishes Ukraine/Russia Related CAATSA Guidance

Posted by Matt Schmitt on 11/3/17 2:40 PM

On October 31, 2017, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued the amended Ukraine-/Russia-Related Directive 4 Under Executive Order 13662 in accordance with the Countering America’s Adversaries Through Sanctions Act (CAATSA).

The amended directive adds to the previous version of Directive 4 a prohibition of activities in the United States, or by US persons, that include “the provision, exportation, or reexportation, directly or indirectly, of goods, services … or technology in support of exploration or production for deepwater, Arctic offshore, or shale projects … that are initiated after January 29, 2018, that have the potential to produce oil in any location” by persons subject to the Directive if they, their property, or their interests in property have “a 33 percent or greater ownership interest, or … ownership of a majority of the voting interest.”

The press release can be found here:

https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20171031.aspx

The amended Directive can be found here:

https://www.treasury.gov/resource-center/sanctions/Programs/Documents/eo13662_directive4_20171031.pdf

 

OFAC has additional FAQs located here:

https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_other.aspx#373

https://www.treasury.gov/resource-center/sanctions/Programs/Pages/caatsa.aspx#faqs_titleii

Topics: OFAC, Ukraine, Russia, CAATSA

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