November 1, 2017
Yesterday, in accordance with the Countering America’s Adversaries Through Sanctions Act (“CAATSA”), OFAC amended Ukraine/Russia-related Directive 4. Specifically, the revised Directive 4 includes a new prohibition banning U.S. persons, and those within the United States, from providing, exporting, or reexporting, directly or indirectly, goods, services (except for financial services), or technology in support of exploration or production for deepwater, Arctic offshore, or shale projects that meet all three of the following criteria: (1) the project was initiated on or after January 29, 2018; (2) the project has the potential to produce oil in any location; and (3) any person determined to be subject to Directive 4 (or any earlier version of Directive 4), including their property or interests in property, has either a 33 percent or greater ownership interest in the project, or owns a majority of the voting interests in the project. This prohibition will likely have a significant impact on the oil and gas industry as it will soon apply to deepwater, Arctic offshore, or shale projects in any location (not just in Russia) and will include certain projects in which a person subject to Directive 4 has a non-controlling interest. OFAC also published new and updated FAQs related to amended Directive 4, as well as other CAATSA-related FAQs.
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