September 2014
Update on U.S. Sanctions Relating to Russia
Practice Group(s):
By Jerome J. Zaucha, Daniel J. Gerkin, Donald W. Smith
International Trade
Please find below a summary of recent developments regarding U.S. sanctions relating to
Russia and a summary of the U.S. sanctions to date.
International
Arbitration
Global Government
Solutions
U.S. Sanctions
On September 12, the United States imposed additional sanctions relating to Russia in
connection with events in Ukraine. Specifically,
1. the Office of Foreign Assets Control, U.S. Department of the Treasury (“OFAC”): (i)
placed additional Russian persons on OFAC’s Specially Designated Nationals and
Blocked Persons (“SDN”) list; (ii) placed additional Russian persons on OFAC’s
Sectoral Sanctions Identifications List (“SSIL”); (iii) amended the bar on activities by U.S.
persons relating to debt of SSIL-listed persons from the Russian financial services sector
to cover new debt of more than 30 days maturity (previously the bar related to debt of 90
days or longer); (iv) imposed a bar on activities by U.S. persons relating to new debt of
more than 30 days maturity of SSIL-listed persons from the Russian defense and related
materiel sector; and (v) imposed a bar on activities by U.S. persons in support of
deepwater, Arctic offshore, or shale exploration or production projects that have the
potential to produce oil in Russia and that involve any person designated on the SSIL in
connection with the bar; and
2. the Bureau of Industry and Security, U.S. Department of Commerce (“BIS”): (i) added five
entities from the Russian defense or related material sector to the BIS Entity List; (ii)
added five entities from the Russian energy sector to the BIS Entity List, which are now
subject to an export licensing requirement for certain energy projects; and (iii) imposed an
export licensing requirement on certain Commerce Control List items known to be
destined to Russia for a military end use or user (expanding the current licensing
requirement for such exports to China to also cover Russia).
1. New OFAC Measures.
New Listings. OFAC placed additional Russian persons on OFAC’s SDN list and SSIL,
including, in the case of the SSIL, designations in the Russian defense and related material
and energy sectors in connection with Directives 3 and 4, described below. Notably,
Sberbank, Russia’s largest bank, which previously had been spared inclusion, was added to
the SSIL under Directive 1. The changes to these OFAC lists are detailed in Appendix A.
New Directive 3. On September 12, OFAC issued Directive 3 under its Ukraine sanctions,
which prohibits U.S. persons from engaging in activities relating to new debt of longer than
30 days maturity of persons from the Russian defense and related materiel sector
designated on the SSIL under Directive 3. Specifically, Directive 3 prohibits “all transactions
in, provision of financing for, and other dealings in new debt of longer than 30 days maturity
of persons determined to be subject to [Directive 3], their property, or their interests in
property.”
Update on U.S. Sanctions Relating to Russia
In addition, OFAC also amended Directive 1, which relates to SSIL designations in the
Russian financial sector, reducing the term of debt covered by that Directive from longer than
90 days to longer than 30 days. The term of debt covered by Directive 2, which relates to
SSIL designations in the energy sector, remains unchanged and continues to cover new debt
of longer than 90 days maturity.
New Directive 4. On September 12, OFAC also issued Directive 4, which introduces a new
prohibition on activities by U.S. persons relating to certain energy projects in
Russia. Directive 4 prohibits “the provision, exportation, or reexportation, directly or
indirectly, of goods, services (except for financial services), or technology in support of
exploration or production for deepwater, Arctic offshore, or shale projects that have the
potential to produce oil in the Russian Federation, or in maritime area claimed by the
Russian Federation,” involving any person designated on the SSIL under Directive 4.
According to OFAC guidance, “the prohibition on the exportation of services includes, for
example, drilling services, geophysical services, geological services, logistical services,
management services, modeling capabilities, and mapping technologies,” but “[t]he
prohibition does not apply to the provision of financial services” (emphasis in the original).
On September 12, 2014, OFAC also issued General License 2, authorizing “all activities
prohibited by Directive 4 . . . that are ordinarily incident and necessary to the wind down of
operations, contracts, or other agreements involving persons determined to be subject to
Directive 4 . . . and that were in effect prior to September 12, 2014” through 12:01 a.m.
eastern daylight time, September 26, 2014.
2. New BIS Measures.
Entity List. BIS added certain persons from the Russian defense or related material and
energy sectors to the BIS Entity List. This means that exports to such persons, as described
in the terms of the listing, of items that are subject to the EAR will require a license, including
exports of such items by non-U.S. persons who would not otherwise be subject to OFAC’s
Directive 4. In the case of the energy sector companies listed, the licensing requirement
applies “when the exporter, reexporter or transferor knows that the item will be used directly
or indirectly in exploration for, or production of, oil or gas in Russian deepwater (greater than
500 feet) or Arctic offshore locations or shale formations in Russia.” Further, license
applications for such projects that have the potential to produce oil will be reviewed with a
presumption of denial:
Persons operating in the Russian defense or related material sector added to BIS
Entity List:
1. Almaz-Antey Air Defense Concern Main System Design Bureau, JSC;
2. Tikhomirov Scientific Research Institute of Instrument Design, JSC
3. Kalinin Machine Plant, JSC;
4. Mytishchinski Mashinostroitelny Zavod, OAO; and
5. Dolgoprudny Research Production Enterprise, OAO.
2
Update on U.S. Sanctions Relating to Russia
Persons operating in the Russian energy sector added to BIS Entity List:
1. Gazprom, OAO;
2. Gazprom Neft;
3. Lukoil, OAO;
4. Rosneft; and
5. Surgutneftegas.
New Licensing Requirement for Military End Uses and Users. BIS previously
established an export licensing requirement under Section 744.21 of the Export
Administration Regulations (“EAR”) for certain items on the Commerce Control List when it is
known the item is destined for a military end use or end user in China (which otherwise do
not require a license for export to China). BIS has amended Section 744.21 to extend the
licensing requirement for such items when it is known they are destined for a military end
user or end use in Russia (which also otherwise do not require a license for export to
Russia). The items that are subject to these license requirements are those listed in
Supplement No. 2 to Part 744 of the EAR.
OVERVIEW OF U.S. SANCTIONS RELATING TO RUSSIA/UKRAINE TO DATE
OFAC Sanctions
• Certain Russian and Ukrainian persons have been added to the OFAC SDN list and,
as such, the property or interests in property of the listed persons that are in the U.S.
or in the possession or control of a U.S. person (defined as an individual who is a
citizen or resident of the U.S. or an entity organized or located in the U.S. and their
non-U.S. branches) are blocked and no transactions by U.S. persons or from the
U.S. with such SDNs are permitted;
• Certain Russian financial services, defense and related materiel, and energy sector
entities have been placed on the newly established SSIL. U.S. persons are barred
from involvement in activities relating to the issuance of new equity or new long term
debt (from July 16 to September 12, with a term of 90 days or longer, and, as of
September 12, 2014, with a term of 30 days or longer) for the financial sector entities
(listed on the SSIL under OFAC Directive 1), new long term debt (90 days or longer)
for the energy sector entities (listed on the SSIL under OFAC Directive 2), and new
debt of longer than 30 days for the defense and related material sector entities (listed
on the SSIL under OFAC Directive 3). Please note that long term payment terms in
connection with the supply of goods or services can be considered a long term debt
and a failure by a listed person to pay in less than the period prescribed as long term
debt can give rise to an OFAC reporting requirement; and
3
Update on U.S. Sanctions Relating to Russia
• U.S. persons may not engage in any activities relating to exploration or production for
deepwater, Arctic offshore, or shale projects that have the potential to produce oil in
Russia and that involve any person in the energy sector designated on the SSIL in
connection with the bar (under Directive 4).
BIS Restrictions
• Certain Russian persons have been placed on the Entity List under the EAR, which
means any item described in the listing (usually any item subject to the EAR)
requires a license to be exported or otherwise transferred to such persons. In the
case of certain persons listed from the Russian energy sector, the licensing
requirement applies to items that “will be used directly or indirectly in exploration for,
or production of, oil or gas in Russian deepwater (greater than 500 feet) or Arctic
offshore locations or shale formations in Russia;”
• Items classified under Export Control Classification Numbers (“ECCNs”) designated
under the new EAR Russian Industry Sector Sanctions (see Section 746.5 of the
EAR) or covered by a Schedule B Number listed on the Russian Industry Sector
Sanctions List (in Supplement 2 to Part 746 of the EAR) require a license under the
EAR if the exporter or reexporter knows or is informed the item will be used directly
or indirectly in designated Russian energy sector applications (including for
exploration or production from deepwater (greater than 500 feet), Arctic offshore, or
shale projects in Russia that have the potential to produce oil or gas) or is unable to
determine whether the item will be used in such projects in Russia. Please note
there have been some modifications to the ECCN descriptions and the addition of a
new ECCN for purposes of the Russian Industry Sector Sanctions List and,
accordingly, the ECCN for any items sought to be supplied should be reevaluated
under the post Sanctions ECCN descriptions. Also note that BIS has implemented a
licensing policy of presumptive denial for all items subject to the EAR requiring a
license for export to Russia in connection with Russian oil projects, including items
not within the above-described ECCNs or Schedule B Numbers. Since gas projects
were not included in the policy of presumptive denial, it is assumed that license
applications for gas projects will be reviewed on a case-by-case basis;
• BIS also announced a policy under the EAR that it will deny licenses to export or
reexport any high technology item subject to the EAR to Russia or occupied Crimea
that could contribute to Russia’s military capabilities; and
• The licensing requirement under the EAR for certain Commerce Control List items
when exported or transferred with knowledge the item is intended for a military end
use or end user in China has been extended to such exports to Russia.
4
Update on U.S. Sanctions Relating to Russia
U.S. Department of State’s Directorate of Defense Trade Controls (“DDTC”)
Restrictions
• The DDTC implemented a tightened policy to deny pending export license
applications for any high technology items that could contribute to Russia’s military
capabilities. DDTC is revoking any existing export licenses that meet these
conditions and all other pending applications and existing licenses are receiving a
case-by-case evaluation to determine their contribution to Russia’s military
capabilities.
Should you have any questions regarding the latest or historical sanctions, please do not
hesitate to contact the authors.
5
Update on U.S. Sanctions Relating to Russia
APPENDIX A
The following entities have been added to OFAC’s SDN List:
JOINT STOCK COMPANY ALMAZ-ANTEY AIR DEFENSE CONCERN MAIN SYSTEM
DESIGN BUREAU NAMED BY ACADEMICIAN A.A. RASPLETIN (a.k.a. A.A. RASPLETIN
MAIN SYSTEM DESIGN BUREAU; a.k.a. ALMAZ-ANTEY GSKB; a.k.a. ALMAZ-ANTEY
GSKB IMENI ACADEMICIAN A.A. RASPLETIN; a.k.a. ALMAZ-ANTEY MSDB; a.k.a.
ALMAZ-ANTEY PVO ‘AIR DEFENSE’ CONCERN LEAD SYSTEMS DESIGN BUREAU OAO
‘OPEN JOINT-STOCK COMPANY’ IMENI ACADEMICIAN A.A. RASPLETIN; a.k.a.
GOLOVNOYE SISTEMNOYE KONSTRUKTORSKOYE BYURO OPEN JOINT-STOCK
COMPANY OF ALMAZ-ANTEY PVO CONCERN IMENI ACADEMICIAN A.A. RASPLETIN;
a.k.a. JSC ‘ALMAZ-ANTEY’ MSDB; f.k.a. OTKRYTOE AKTSIONERNOE OBSHCHESTVO
NAUCHNO PROIZVODSTVENNOE OBEDINENIE ALMAZ IMENI AKADEMIKA A.A.
RASPLETINA; a.k.a. “GSKB”), 16-80, Leningradsky Prospect, Moscow 125190, Russia;
website http://www.raspletin.ru/; e-mail address info@raspletin.ru; alt. e-mail address
almaz_zakupki@mail.ru [UKRAINE-EO13661].
JSC V. TIKHOMIROV SCIENTIFIC RESEARCH INSTITUTE OF INSTRUMENT DESIGN
(a.k.a. JSC NIIP; f.k.a. OTKRYTOE AKTSIONERNOE OBSHCHESTVO NAUCHNO
ISSLEDOVATELSKI INSTITUT PRIBOROSTROENIYA IMENI V.V. TIKHOMIROVA), 3 Ul.
Gagarina, Zhukovski, Moskovskaya Obl 140180, Russia; Gagarin Str, 3, Zhukovsky 140180,
Russia; website http://www.niip.ru; e-mail address niip@niip.ru; Registration ID
1025001627859; Government Gazette Number 13185231 (Russia) [UKRAINE-EO13661].
KALININ MACHINE PLANT JSC (a.k.a. KALININ MACHINE-BUILDING PLANT OPEN
JOINT-STOCK COMPANY; a.k.a. KALININ MACHINERY PLANT-BRD; a.k.a.
MASHINOSTROITEL’NYI ZAVOD IM. M.I. KALININA, G. YEKATERINBURG OAO; a.k.a.
MZIK OAO; a.k.a. OPEN-END JOINT-STOCK COMPANY ‘KALININ MACHINERY PLANT.
YEKATERINBURG’; a.k.a. OTKRYTOE AKTSIONERNOE OBSHCHESTVO
MASHINOSTROITELNY ZAVOD IM.M.I.KALININA, G.EKATERINBURG), 18 prospekt
Kosmonavtov, Ekaterinburg, Sverdlovskaya obl. 620017, Russia; e-mail address info@zik.ru
[UKRAINE-EO13661].
MYTISHCHINSKI MASHINOSTROITELNY ZAVOD, OAO (a.k.a. JSC MYTISHCHINSKI
MACHINE-BUILDING PLANT; a.k.a. OTKRYTOE AKTSIONERNOE OBSHCHESTVO
‘MYTISHCHINSKI MASHINOSTROITELNY ZAVOD’), 4 ul. Kolontsova Mytishchi,
Mytishchinski Raion, Moskovskayaobl 141009, Russia; UL. Koloncova, d.4, Mytishi, Moscow
region 141009, Russia; website www.mmzavod.ru; e-mail address mmzavod@mail.ru;
Registration ID 1095029003860 (Russia); Government Gazette Number 61540868 (Russia)
[UKRAINE-EO13661].
OAO ‘DOLGOPRUDNY RESEARCH PRODUCTION ENTERPRISE’ (a.k.a.
DOLGOPRUDNENSKOYE NPP OAO; a.k.a. DOLGOPRUDNY; a.k.a. DOLGOPRUDNY
RESEARCH PRODUCTION ENTERPRISE; a.k.a. OTKRYTOE AKTSIONERNOE
OBSHCHESTVO DOIGOPRUDNENSKOE NAUCHNO PROIZVODSTVENNOE
PREDPRIYATIE), 1 Pl. Sobina, Dolgoprudny, Moskovskaya obl. 141700, Russia; Proshchad
Sobina 1, Dolgoprudny 141700, Russia; e-mail address dnpp@orc.ru; Registration ID
6
Update on U.S. Sanctions Relating to Russia
1025001202544; Tax ID No. 5008000322; Government Gazette Number 07504318
[UKRAINE-EO13661].
The following entities have been added to OFAC’s Sectoral Sanctions Identifications
List:
AK TRANSNEFT OAO (a.k.a. AKTSIONERNAYA KOMPANIYA PO TRANSPORTUNEFTI
TRANSNEFT OAO; a.k.a. OAO AK TRANSNEFT; a.k.a. OIL TRANSPORTING JOINTSTOCK COMPANY TRANSNEFT; a.k.a. TRANSNEFT; a.k.a. TRANSNEFT OJSC; a.k.a.
TRANSNEFT, JSC), 57 B. Polyanka ul., Moscow 119180, Russia; 57 Bolshaya. Polyanka,
Moscow 119180, Russia; website www.transneft.ru; e-mail address
transneft@ak.transneft.ru; Executive Order 13662 Directive Determination - Subject to
Directive 2; Registration ID 1027700049486; Tax ID No. 7706061801; Government Gazette
Number 00044463; For more information on directives, please visit the following link:
http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives.
[UKRAINE-EO13662].
LUKOIL OAO (a.k.a. LUKOIL; a.k.a. LUKOIL OIL COMPANY; a.k.a. NEFTYANAYA
KOMPANIYA LUKOIL OOO; a.k.a. NK LUKOIL OAO), 11 Sretenski boulevard, Moscow
101000, Russia; website www.lukoil.ru; e-mail address info@lukoil.ru; Executive Order
13662 Directive Determination - Subject to Directive 4; Registration ID 1027700035769; Tax
ID No. 7708004767; Government Gazette Number 00044434; For more information on
directives, please visit the following link: http://www.treasury.gov/resourcecenter/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662].
OJSC GAZPROM NEFT (a.k.a. GAZPROM NEFT OAO; a.k.a. JSC GAZPROM NEFT; a.k.a.
OPEN JOINT-STOCK COMPANY GAZPROM NEFT; f.k.a. SIBIRSKAYA NEFTYANAYA
KOMPANIYA OAO), Let. A. Galernaya, 5, ul, St. Petersburg 190000, Russia; Ul.
Pochtamtskaya, 3-5, St. Petersburg 190000, Russia; 3-5 Pochtamtskaya St., St. Petersburg
190000, Russia; 125 A. Profsoyuznaya Street, Moscow 117647, Russia; website
http://www.gazprom-neft.com/; e-mail address info@gazprom-neft.ru; alt. e-mail address
pr@gazprom-neft.ru; alt. e-mail address shareholders@gazprom-neft.ru; alt. e-mail address
ir@gazprom-neft.ru; Executive Order 13662 Directive Determination - Subject to Directive 2;
alt. Executive Order 13662 Directive Determination - Subject to Directive 4; Registration ID
1025501701686; Tax ID No. 5504036333; Government Gazette Number 42045241; For
more information on directives, please visit the following link:
http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives.
[UKRAINE-EO13662].
OPEN JOINT STOCK COMPANY GAZPROM (a.k.a. GAZPROM OAO; a.k.a. OAO
GAZPROM), 16 Nametkina St., Moscow, Russia GSP-7, 117997, Russia; 16 Nametkina ul.,
Moscow 117991, Russia; website www.gazprom.ru; e-mail address gazprom@gazprom.ru;
Executive Order 13662 Directive Determination - Subject to Directive 4; Registration ID
1027700070518 (Russia); Tax ID No. 7736050003 (Russia); Government Gazette Number
00040778 (Russia); For more information on directives, please visit the following link:
http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives.
[UKRAINE-EO13662].
7
Update on U.S. Sanctions Relating to Russia
ROSTEC (a.k.a. ROSTEC STATE CORPORATION; a.k.a. RUSSIAN TECHNOLOGIES;
a.k.a. RUSSIAN TECHNOLOGIES STATE CORPORATION FOR ASSISTANCE TO
DEVELOPMENT, PRODUCTION AND EXPORT OF ADVANCED TECHNOLOGY
INDUSTRIAL PRODUCT; a.k.a. STATE CORPORATION FOR ASSISTANCE TO
DEVELOPMENT, PRODUCTION AND EXPORT OF ADVANCED TECHNOLOGY
INDUSTRIAL PRODUCT ROSTEKHNOLOGII; a.k.a. STATE CORPORATION
ROSTECHNOLOGII; a.k.a. STATE CORPORATION ROSTEKHNOLOGII), 24 Usacheva ul.,
Moscow 119048, Russia; 21 Gogolevsky Blvd., Moscow 119991, Russia; website
www.rostec.ru; e-mail address info@rostec.ru; Executive Order 13662 Directive
Determination - Subject to Directive 3; Registration ID 1077799030847 (Russia); Tax ID No.
7704274402 (Russia); Government Gazette Number 94137372 (Russia); For more
information on directives, please visit the following link: http://www.treasury.gov/resourcecenter/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662].
SBERBANK OF RUSSIA (f.k.a. OTKRYTOE AKTSIONERNOE OBSHCHESTVO
SBERBANK ROSSII; a.k.a. SBERBANK ROSSII; f.k.a. SBERBANK ROSSII OAO), 19 ul.
Vavilova, Moscow 117997, Russia; SWIFT/BIC SABRRUMM; website www.sberbank.ru; email address sbrf@sbrf.ru; Executive Order 13662 Directive Determination - Subject to
Directive 1; For more information on directives, please visit the following link:
http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives.
[UKRAINE-EO13662].
SURGUTNEFTEGAS (a.k.a. OPEN JOINT STOCK COMPANY SURGUTNEFTEGAS; a.k.a.
OTKRYTOE AKTSIONERNOE OBSHCHESTVO SURGUTNEFTEGAZ; a.k.a.
SURGUTNEFTEGAS OAO; a.k.a. SURGUTNEFTEGAS OJSC; a.k.a. SURGUTNEFTEGAZ
OAO), ul. Grigoriya Kukuyevitskogo, 1, bld. 1, Khanty-Mansiysky Autonomous Okrug Yugra, the city of Surgut, Tyumenskaya Oblast 628415, Russia; korp. 1 1 Grigoriya
Kukuevitskogo ul., Surgut, Tyumenskaya oblast 628404, Russia; Street Kukuevitskogo 1,
Surgut, Tyumen Region 628415, Russia; website www.surgutneftegas.ru; e-mail address
secretary@surgutneftegas.ru; Executive Order 13662 Directive Determination - Subject to
Directive 4; For more information on directives, please visit the following link:
http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives.
[UKRAINE-EO13662].
The following changes have been made to OFAC’s Sectoral Sanctions Identifications
List:
BANK OF MOSCOW (f.k.a. AKTSIONERNY KOMMERCHESKI BANK BANK MOSKVY,
OTKRYTOE AKTSIONERNOE OBSCHCHESTVO; a.k.a. JOINT STOCK COMMERCIAL
BANK - BANK OF MOSCOW, OPEN JOINT STOCK COMPANY), 8/15 Korp. 3 ul.
Rozhdestvenka, Moscow 107996, Russia; Bld 3 8/15, Rozhdestvenka St., Moscow 107996,
Russia; SWIFT/BIC MOSW RU MM; website www.bm.ru; e-mail address
holmogorov_ss@mmbank.ru; alt. e-mail address info@mmbank.ru; BIK (RU) 044525219;
Registration ID 1027700159497; Government Gazette Number 29292940; The following
transactions by U.S. persons or within the United States are hereby prohibited: transacting
in, providing financing for, or otherwise dealing in new debt of longer than 90 days maturity
8
Update on U.S. Sanctions Relating to Russia
or new equity for these persons (listed here), their property, or their interests in property. All
other transactions with these persons or involving any property in which one or more of these
persons has an interest are permitted, provided such transactions do not otherwise involve
property or interests in property of a person blocked pursuant to Executive Orders 13660,
13661, or 13662, or any other sanctions programs implemented by the Office of Foreign
Assets Control. [UKRAINE-EO13662]. -to- BANK OF MOSCOW (f.k.a. AKTSIONERNY
KOMMERCHESKI BANK BANK MOSKVY, OTKRYTOE AKTSIONERNOE
OBSCHCHESTVO; a.k.a. JOINT STOCK COMMERCIAL BANK - BANK OF MOSCOW,
OPEN JOINT STOCK COMPANY)|, 8/15 Korp. 3 ul. Rozhdestvenka, Moscow 107996,
Russia; Bld 3 8/15, Rozhdestvenka St., Moscow 107996, Russia; SWIFT/BIC MOSW RU
MM; website www.bm.ru; e-mail address holmogorov_ss@mmbank.ru; alt. e-mail address
info@mmbank.ru; BIK (RU) 044525219; Executive Order 13662 Directive Determination Subject to Directive 1; Registration ID 1027700159497; Government Gazette Number
29292940; For more information on directives, please visit the following link:
http://www.treasury.gov/resourcecenter/sanctions/Programs/Pages/ukraine.aspx#directives.| [UKRAINE-EO13662].
GAZPROMBANK OAO (a.k.a. GAZPROMBANK GAS INDUSTRY OJSC; a.k.a.
GAZPROMBANK OJSC; a.k.a. GAZPROMBANK OPEN JOINT STOCK COMPANY; a.k.a.
GAZPROMBANK OTKRYTOE AKTSIONERNOE OBSHCHESTVO; a.k.a. GPB, OAO; a.k.a.
GPB, OJSC), 16, Building 1, Nametkina St., Moscow 117420, Russia; 63,
Novocheremushkinskaya St., Moscow 117418, Russia; SWIFT/BIC GAZPRUMM; website
www.gazprombank.ru; e-mail address mailbox@gazprombank.ru; Registration ID
1027700167110; Tax ID No. 7744001497; Government Gazette Number 09807684; The
following transactions by U.S. persons or within the United States are hereby prohibited:
transacting in, providing financing for, or otherwise dealing in new debt of longer than 90
days maturity or new equity for these persons (listed here), their property, or their interests in
property. All other transactions with these persons or involving any property in which one or
more of these persons has an interest are permitted, provided such transactions do not
otherwise involve property or interests in property of a person blocked pursuant to Executive
Orders 13660, 13661, or 13662, or any other sanctions programs implemented by the Office
of Foreign Assets Control. [UKRAINE-EO13662]. -to- GAZPROMBANK OAO (a.k.a.
GAZPROMBANK GAS INDUSTRY OJSC; a.k.a. GAZPROMBANK OJSC; a.k.a.
GAZPROMBANK OPEN JOINT STOCK COMPANY; a.k.a. GAZPROMBANK OTKRYTOE
AKTSIONERNOE OBSHCHESTVO; a.k.a. GPB, OAO; a.k.a. GPB, OJSC)|, 16, Building 1,
Nametkina St., Moscow 117420, Russia; 63, Novocheremushkinskaya St., Moscow 117418,
Russia; SWIFT/BIC GAZPRUMM; website www.gazprombank.ru; e-mail address
mailbox@gazprombank.ru; Executive Order 13662 Directive Determination - Subject to
Directive 1; Registration ID 1027700167110; Tax ID No. 7744001497; Government Gazette
Number 09807684; For more information on directives, please visit the following link:
http://www.treasury.gov/resourcecenter/sanctions/Programs/Pages/ukraine.aspx#directives.| [UKRAINE-EO13662].
OAO NOVATEK (a.k.a. FINANSOVO-INVESTITSIONNAYA KOMPANIYA NOVAFININVEST
OAO; a.k.a. NOVATEK), 2, Udaltsova Street, Moscow 119415, Russia; 22 A, Pobedy Street,
Tarko-Sale, Yamalo-Nenets Autonomous District 629580, Russia; 22a Pobedy ul., TarkoSale, Purovski raion, Tyumenskaya Oblast 629850, Russia; e-mail address
9
Update on U.S. Sanctions Relating to Russia
novatek@novatek.ru; Registration ID 1026303117642 (Russia); Government Gazette
Number 33556474 (Russia); The following transactions by U.S. persons or within the United
States are hereby prohibited: transacting in, providing financing for, or otherwise dealing in
new debt of longer than 90 days maturity for these persons (listed here), their property, or
their interests in property. All other transactions with these persons or involving any property
in which one or more of these persons has an interest are permitted, provided such
transactions do not otherwise involve property or interests in property of a person blocked
pursuant to Executive Orders 13660, 13661, or 13662, or any other sanctions programs
implemented by the Office of Foreign Assets Control. [UKRAINE-EO13662]. -to- OAO
NOVATEK (a.k.a. FINANSOVO-INVESTITSIONNAYA KOMPANIYA NOVAFININVEST
OAO; a.k.a. NOVATEK)|, 2, Udaltsova Street, Moscow 119415, Russia; 22 A, Pobedy
Street, Tarko-Sale, Yamalo-Nenets Autonomous District 629580, Russia; 22a Pobedy ul.,
Tarko-Sale, Purovski raion, Tyumenskaya Oblast 629850, Russia; e-mail address
novatek@novatek.ru; Executive Order 13662 Directive Determination - Subject to Directive
2; Registration ID 1026303117642 (Russia); Government Gazette Number 33556474
(Russia); For more information on directives, please visit the following link:
http://www.treasury.gov/resourcecenter/sanctions/Programs/Pages/ukraine.aspx#directives.| [UKRAINE-EO13662].
OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY (a.k.a. OAO ROSNEFT OIL
COMPANY; a.k.a. OIL COMPANY ROSNEFT; a.k.a. OJSC ROSNEFT OIL COMPANY;
a.k.a. ROSNEFT; a.k.a. ROSNEFT OIL COMPANY), 26/1 Sofiyskaya Embankment, Moscow
115035, Russia; website www.rosneft.com; alt. website www.rosneft.ru; e-mail address
postman@rosneft.ru; Registration ID 1027700043502 (Russia); Tax ID No. 7706107510
(Russia); Government Gazette Number 00044428 (Russia); The following transactions by
U.S. persons or within the United States are hereby prohibited: transacting in, providing
financing for, or otherwise dealing in new debt of longer than 90 days maturity for these
persons (listed here), their property, or their interests in property. All other transactions with
these persons or involving any property in which one or more of these persons has an
interest are permitted, provided such transactions do not otherwise involve property or
interests in property of a person blocked pursuant to Executive Orders 13660, 13661, or
13662, or any other sanctions programs implemented by the Office of Foreign Assets
Control. [UKRAINE-EO13662]. -to- OPEN JOINT-STOCK COMPANY ROSNEFT OIL
COMPANY (a.k.a. OAO ROSNEFT OIL COMPANY; a.k.a. OIL COMPANY ROSNEFT;
a.k.a. OJSC ROSNEFT OIL COMPANY; a.k.a. ROSNEFT; a.k.a. ROSNEFT OIL
COMPANY)|, 26/1 Sofiyskaya Embankment, Moscow 115035, Russia; website
www.rosneft.com; alt. website www.rosneft.ru; e-mail address postman@rosneft.ru;
Executive Order 13662 Directive Determination - Subject to Directive 2; alt. Executive Order
13662 Directive Determination - Subject to Directive 4; Registration ID 1027700043502
(Russia); Tax ID No. 7706107510 (Russia); Government Gazette Number 00044428
(Russia); For more information on directives, please visit the following link:
http://www.treasury.gov/resourcecenter/sanctions/Programs/Pages/ukraine.aspx#directives.| [UKRAINE-EO13662].
RUSSIAN AGRICULTURAL BANK (f.k.a. OTKRYTOE AKTSIONERNOE ROSSISKI
SELSKOKHOZYAISTVENNY BANK; a.k.a. ROSSELKHOZBANK; a.k.a. ROSSIYSKI
SELSKOKHOZYAISTVENNY BANK OAO; a.k.a. RUSSIAN AGRICULTURAL BANK OAO),
10
Update on U.S. Sanctions Relating to Russia
3, Gagarinsky Pereulok, Moscow 119034, Russia; 3 Gagarinsky per., Moscow 119034,
Russia; SWIFT/BIC RUAG RU MM; website http://www.rshb.ru; e-mail address
office@rshb.ru; Registration ID 1027700342890; Government Gazette Number 52750822;
The following transactions by U.S. persons or within the United States are hereby prohibited:
transacting in, providing financing for, or otherwise dealing in new debt of longer than 90
days maturity or new equity for these persons (listed here), their property, or their interests in
property. All other transactions with these persons or involving any property in which one or
more of these persons has an interest are permitted, provided such transactions do not
otherwise involve property or interests in property of a person blocked pursuant to Executive
Orders 13660, 13661, or 13662, or any other sanctions programs implemented by the Office
of Foreign Assets Control. [UKRAINE-EO13662]. -to- RUSSIAN AGRICULTURAL BANK
(f.k.a. OTKRYTOE AKTSIONERNOE ROSSISKI SELSKOKHOZYAISTVENNY BANK; a.k.a.
ROSSELKHOZBANK; a.k.a. ROSSIYSKI SELSKOKHOZYAISTVENNY BANK OAO; a.k.a.
RUSSIAN AGRICULTURAL BANK OAO)|, 3, Gagarinsky Pereulok, Moscow 119034,
Russia; 3 Gagarinsky per., Moscow 119034, Russia; SWIFT/BIC RUAG RU MM; website
http://www.rshb.ru; e-mail address office@rshb.ru; Executive Order 13662 Directive
Determination - Subject to Directive 1; Registration ID 1027700342890; Government Gazette
Number 52750822; For more information on directives, please visit the following link:
http://www.treasury.gov/resourcecenter/sanctions/Programs/Pages/ukraine.aspx#directives.| [UKRAINE-EO13662].
VNESHECONOMBANK (a.k.a. BANK FOR DEVELOPMENT AND FOREIGN ECONOMIC
AFFAIRS (VNESHECONOMBANK) STATE CORPORATION; a.k.a. BANK RAZVITIYA I
VNESHNEEKONOMICHESKOI DEYATELNOSTI (VNESHEKONOMBANK)
GOSUDARSTVENNAYA KORPORATSIYA; a.k.a. “VEB”), 9 Akademika Sakharova
prospekt, Moscow 107996, Russia; SWIFT/BIC BFEA RU MM; website http://www.veb.ru; email address info@veb.ru; BIK (RU) 044525060; The following transactions by U.S. persons
or within the United States are hereby prohibited: transacting in, providing financing for, or
otherwise dealing in new debt of longer than 90 days maturity or new equity for these
persons (listed here), their property, or their interests in property. All other transactions with
these persons or involving any property in which one or more of these persons has an
interest are permitted, provided such transactions do not otherwise involve property or
interests in property of a person blocked pursuant to Executive Orders 13660, 13661, or
13662, or any other sanctions programs implemented by the Office of Foreign Assets
Control. [UKRAINE-EO13662]. -to- VNESHECONOMBANK (a.k.a. BANK FOR
DEVELOPMENT AND FOREIGN ECONOMIC AFFAIRS (VNESHECONOMBANK) STATE
CORPORATION; a.k.a. BANK RAZVITIYA I VNESHNEEKONOMICHESKOI
DEYATELNOSTI (VNESHEKONOMBANK) GOSUDARSTVENNAYA KORPORATSIYA;
a.k.a. “VEB”)|, 9 Akademika Sakharova prospekt, Moscow 107996, Russia; SWIFT/BIC
BFEA RU MM; website http://www.veb.ru; e-mail address info@veb.ru; BIK (RU) 044525060;
Executive Order 13662 Directive Determination - Subject to Directive 1; For more information
on directives, please visit the following link: http://www.treasury.gov/resourcecenter/sanctions/Programs/Pages/ukraine.aspx#directives.| [UKRAINE-EO13662].
VTB BANK OAO (f.k.a. BANK VNESHNEY TORGOVLI ROSSIYSKOY FEDERATSII,
CLOSED JOINT-STOCK COMPANY; f.k.a. BANK VNESHNEY TORGOVLI RSFSR; f.k.a.
BANK VNESHNEY TORGOVLI, JOINT-STOCK COMPANY; f.k.a. BANK VNESHNEY
11
Update on U.S. Sanctions Relating to Russia
TORGOVLI, OPEN JOINT-STOCK COMPANY; a.k.a. BANK VTB OAO; a.k.a. BANK VTB,
OPEN JOINT-STOCK COMPANY; a.k.a. JSC VTB BANK; f.k.a. VNESHTORGBANK; f.k.a.
VNESHTORGBANK ROSSII, CLOSED JOINT-STOCK COMPANY; a.k.a. VTB BANK,
OPEN JOINT-STOCK COMPANY), 29, Bolshaya Morskaya str., St. Petersburg 190000,
Russia; 37 Plyushchikha ul., Moscow 119121, Russia; 43, Vorontsovskaya str., Moscow
109044, Russia; SWIFT/BIC VTBRRUMM; website www.vtb.com; Registration ID
1027739609391 (Russia); Tax ID No. 7702070139 (Russia); Government Gazette Number
00032520 (Russia); License 1000 (Russia); The following transactions by U.S. persons or
within the United States are hereby prohibited: transacting in, providing financing for, or
otherwise dealing in new debt of longer than 90 days maturity or new equity for these
persons (listed here), their property, or their interests in property. All other transactions with
these persons or involving any property in which one or more of these persons has an
interest are permitted, provided such transactions do not otherwise involve property or
interests in property of a person blocked pursuant to Executive Orders 13660, 13661, or
13662, or any other sanctions programs implemented by the Office of Foreign Assets
Control. [UKRAINE-EO13662]. -to- VTB BANK OAO (f.k.a. BANK VNESHNEY TORGOVLI
ROSSIYSKOY FEDERATSII, CLOSED JOINT-STOCK COMPANY; f.k.a. BANK
VNESHNEY TORGOVLI RSFSR; f.k.a. BANK VNESHNEY TORGOVLI, JOINT-STOCK
COMPANY; f.k.a. BANK VNESHNEY TORGOVLI, OPEN JOINT-STOCK COMPANY; a.k.a.
BANK VTB OAO; a.k.a. BANK VTB, OPEN JOINT-STOCK COMPANY; a.k.a. JSC VTB
BANK; f.k.a. VNESHTORGBANK; f.k.a. VNESHTORGBANK ROSSII, CLOSED JOINTSTOCK COMPANY; a.k.a. VTB BANK, OPEN JOINT-STOCK COMPANY)|, 29, Bolshaya
Morskaya str., St. Petersburg 190000, Russia; 37 Plyushchikha ul., Moscow 119121, Russia;
43, Vorontsovskaya str., Moscow 109044, Russia; SWIFT/BIC VTBRRUMM; website
www.vtb.com; Executive Order 13662 Directive Determination - Subject to Directive 1;
Registration ID 1027739609391 (Russia); Tax ID No. 7702070139 (Russia); Government
Gazette Number 00032520 (Russia); License 1000 (Russia); For more information on
directives, please visit the following link: http://www.treasury.gov/resourcecenter/sanctions/Programs/Pages/ukraine.aspx#directives.| [UKRAINE-EO13662].
Authors:
Jerome J. Zaucha
Daniel J. Gerkin
Donald W. Smith
jerome.zaucha@klgates.com
+1.202.778.9013
daniel.gerkin@klgates.com
+1.202.778.9168
donald.smith@klgates.com
+1.212.778.9079
12
Update on U.S. Sanctions Relating to Russia
Anchorage Austin Beijing Berlin Boston Brisbane Brussels Charleston Charlotte Chicago Dallas Doha Dubai Fort Worth Frankfurt
Harrisburg Hong Kong Houston London Los Angeles Melbourne Miami Milan Moscow Newark New York Orange County Palo Alto Paris
Perth Pittsburgh Portland Raleigh Research Triangle Park San Diego San Francisco São Paulo Seattle Seoul Shanghai Singapore Spokane
Sydney Taipei Tokyo Warsaw Washington, D.C. Wilmington
K&L Gates practices out of 48 fully integrated offices located in the United States, Asia, Australia, Europe, the
Middle East and South America and represents leading global corporations, growth and middle-market companies,
capital markets participants and entrepreneurs in every major industry group as well as public sector entities,
educational institutions, philanthropic organizations and individuals. For more information about K&L Gates or its
locations, practices and registrations, visit www.klgates.com.
This publication is for informational purposes and does not contain or convey legal advice. The information herein should not be used or relied upon in
regard to any particular facts or circumstances without first consulting a lawyer.
© 2014 K&L Gates LLP. All Rights Reserved.
13