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Rosneft Trading graduates from SSI List to SDN List

Earlier today, OFAC added the following person:

CASIMIRO, Didier, Moscow, Russia; DOB 15 Nov 1966; POB Vilvoorde, Belgium; Gender Male (individual) [VENEZUELA-EO13850] (Linked To: ROSNEFT TRADING S.A.).

and entity:

ROSNEFT TRADING S.A., Rue Place du Lac 2, 1204, Geneva, Switzerland; Website http://www.rosneft.com; Executive Order 13662 Directive Determination – Subject to Directive 2; alt. Executive Order 13662 Directive Determination – Subject to Directive 4; Tax ID No. CHE-309.842.573 (Switzerland); Registration Number CH-660.0.257.011-8 (Switzerland); For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] [VENEZUELA-EO13850] (Linked To: OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY).

to the SDN List under the Venezuela sanctions (and the entity under the Ukraine/Russia program, too). Additionally, the entities’ SSI List entry was updated, too:

ROSNEFT TRADING S.A., 2, Rue Place du Lac, 1204, Geneva, Switzerland; Website http://www.rosneft.com; Executive Order 13662 Directive Determination – Subject to Directive 2; alt. 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] (Linked To: OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY). -to- ROSNEFT TRADING S.A., Rue Place du Lac 2, 1204, Geneva, Switzerland; Website http://www.rosneft.com; Executive Order 13662 Directive Determination – Subject to Directive 2; alt. Executive Order 13662 Directive Determination – Subject to Directive 4; Tax ID No. CHE-309.842.573 (Switzerland); Registration Number CH-660.0.257.011-8 (Switzerland); For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] [VENEZUELA-EO13850] (Linked To: OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY).

You may wonder why OFAC would retain the SSI List listing. Certainly the Directive 2 (debt restrictions) designation is superseded by the general asset freeze. However, you need the Directive 4 designation to reinforce the project participation restrictions – technically, something could be considered to not provide “significant economic benefit” large enough to block the related funds, but might assist a project in which Rosneft Trading had that magical 33% ownership stake.

One last note: because of Section 228 of CAATSA modifying SSIDES, even though it doesn’t explicitly say so in the listing (why is that, actually?), Rosneft Trading is now subject to secondary sanctions.

Link:

OFAC Notice

Categories: OFAC Updates Russia sanctions Sanctions Lists Secondary Sanctions Sectoral Sanctions Sectoral Sanctions Identification (SSI) List Ukraine sanctions Venezuela sanctions

eric9to5

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