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Buckle up, folks – OFAC sanctions Nord Stream 2 AG

On Wednesday, OFAC sanctioned the following person:

WARNIG, Matthias (Cyrillic: ВАРНИГ, Маттиас) (a.k.a. WARNIG, Matthias Arthur (Cyrillic: МАТТИАС, Артур Варниг); a.k.a. WARNIG, Matthias Artur (Cyrillic: АРТУР, Маттиас Варниг)), Zug, Switzerland; Moscow, Russia; Saint Petersburg, Russia; Leipzig, Germany; DOB 26 Jul 1955; POB Altdobern, Brandenburg, Germany; nationality Germany; Gender Male (individual) [PEESA-EO14039].

and entity:

NORD STREAM 2 AG (a.k.a. NEW EUROPEAN PIPELINE AG), Baarerstrasse 52, Zug 6300, Switzerland; Gotthardstrasse 2, Zug 6300, Switzerland; Bahnhofstrasse 10, Zug 6301, Switzerland; Identification Number CHE-444.239.548 (Switzerland); Business Registration Number CH- (Switzerland) [PEESA-EO14039]. 

under its Ukraine-/Russia-related sanctions program, under the PEESA (Protecting Europe’s Energy Security Act)-related Executive Order 14039.

General License 4, which authorized wind-down transactions with Nord Stream 2 AG, was also issued.

And the State Department issued the following press release:

Sanctioning NS2AG, Matthias Warnig, and NS2AG’s Corporate Officers



FEBRUARY 23, 2022Share

The United States applauds Germany’s decision to take administrative steps to halt the certification process for Nord Stream 2, which will prevent the pipeline from becoming operational.  After consultations with Germany and the EU, I have terminated the waiver and imposed sanctions on Nord Stream 2 AG (NS2AG), its CEO Matthias Warnig, and NS2AG’s corporate officers.  This action is in line with the United States’ longstanding opposition to Nord Stream 2 as a Russian geopolitical project and the President’s commitment that Nord Stream 2 would not move forward following the beginning of Russia’s invasion of Ukraine.

I determined on May 19, 2021, in a report to Congress, that NS2AG and Mr. Warnig knowingly facilitated deceptive or structured transactions to provide the pipe-laying vessel Fortuna for the construction of NS2.  I further determined it was in the national interests of the United States to waive sanctions on NS2AG, Mr. Warnig, and NS2AG corporate officers, in order to enable diplomacy with Germany to address the negative impacts of the pipeline, should it become operational.  To this end, on July 21, we joined with Germany to issue the “Joint Statement of the United States and Germany on Support for Ukraine, European Energy Security, and Our Climate Goals.”  This close diplomatic coordination has continued, including throughout Russia’s military build-up in recent months.  Following Russia’s actions this week, the United States and our European allies implemented strong coordinated sanctions, and Germany announced that it was halting the certification process for Nord Stream 2.  In this context, I have determined those waivers are no longer in the national interest of the United States.

As a result of the termination of the waiver of sanctions, NS2AG and Mr. Warnig are now sanctioned under the Protecting Europe’s Energy Security Act (PEESA), implemented through Executive Order (E.O) 14039.  Pursuant to PEESA and E.O. 14039, corporate officers of NS2AG are also subject to visa restrictions.  All property and interests in property of those sanctioned that are in or come within the United States or are in the possession or control of U.S. persons must be blocked and reported to the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC).  Individuals and entities knowingly engaged in sanctionable conduct related to Nord Stream 2 face similar sanctions risks.

The United States remains steadfast in our support for Ukraine’s sovereignty and territorial integrity. Russia’s flagrant disregard for international law in repeatedly invading Ukraine’s sovereign territory demands a firm response from the international community. Our actions today are in line with our commitment, in close coordination with our Allies and partners, to impose massive consequences and severe costs on Russia in response to its unlawful and unprovoked actions in Ukraine. While we remain committed to diplomacy, if Russia continues to escalate its aggression, we are prepared to implement additional unprecedented measures designed to cripple the Russian economy.

Thursday and Friday are going to be busy days – expect massive sanctions from OFAC, the EU, OFSI, Canada and Australia, at a minimum. President Biden is already scheduling a speech for Thursday.


OFAC Notice

General License 4

State Department Press Release

Categories: OFAC Updates PEESA (Protecting Europe’s Energy Security Act) sanctions Russia sanctions Sanctions Lists Ukraine sanctions


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