OFAC Sanctions Rosneft Subsidiary, Issues FAQs, General License
The Treasury’s Office of Foreign Assets Control sanctioned a subsidiary of Rosneft Oil Company and designated its president for supporting the Nicolas Maduro-led regime in Venezuela, Treasury said Feb. 18. OFAC also issued a new general license and two new frequently asked questions that address the “significance” of the designations and clarifies the wind-down period.
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The subsidiary, Rosneft Trading S.A., is a Swiss-incorporated, Russian-controlled oil brokerage firm that is mostly responsible for carrying out Rosneft Oil Company’s foreign projects, Treasury said. Its “core activities” are marketing and distribution, including trading and transporting raw materials, specifically petroleum products. Rosneft Trading’s president and chairman of its board of directors is Didier Casimiro, who OFAC listed as a Specially Designated National.
General License No. 36 authorizes certain wind-down transactions with Rosneft Trading S.A. and its subsidiaries until May 20. The license does not authorize “any debit to an account” belonging to the company. In an FAQ, OFAC said any company that enters into “new business” involving Rosneft Trading S.A. will not qualify for the wind-own authorization. The agency also said that companies unable to complete wind-down activities by May 20 should contact OFAC.
In another FAQ, OFAC clarified that its “blocking sanctions” apply only to Rosneft Trading S.A. and not to Rosneft Oil Company, its “ultimate parent.” U.S. companies and people are not barred from doing business with Rosneft Oil Company “to the extent the proposed dealings do not involve any blocked persons or any other activities prohibited pursuant to any OFAC sanctions authorities,” OFAC said. Rosneft is, however, subject to Ukraine-/Russia-related sanctions stemming from a 2014 designation. “U.S. persons should be mindful of these Ukraine-/Russia-related prohibitions that are relevant in connection with dealings with both Rosneft Oil Company and Rosneft Trading S.A.,” OFAC said.