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Case No. Ukraine-EO13662-2015-324517-1
[ ]
Pioneer Oil Tools Ltd.
Sir William Smith Road
Kirkton Industrial Estate
Arbroath
Angus DD11 3RD
United Kingdom
Dear Ms. [ ]:
This responds to your request of December 1, 2015, and additional correspondence dated January 12, 2016, January 13, 2016, January 21, 2016, January 27, 2016, January 17, 2018, and January 30, 2018 (collectively, the "Application"), to the Office of Foreign Assets Control (OFAC) seeking authorization for Pioneer Oil Tools Ltd. ("Pioneer"), a company located in the United Kingdom to receive payment in U.S. dollars of approximately $221,432.00 from [ ]. According to your Application, it appears that Pioneer sold certain equipment that was to be used by the [ ] for fishing services at Gazprom Flot’s wells, Kirinskoe field, offshore Sakhalin Island, Russia.
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1) Consistent with OFAC’s guidance clarifying the scope of SSI Directive 4, “a gas condensate field with a sea depth of ninety meters and location of 51 degrees north latitude and 143 degrees east longitude” is not a project that is subject to the prohibitions of the directive.
2) The application requests authorization for a non-U.S. company to “receive payment in U.S. dollars of approximately $221,432.00 from an unnamed party, with the applicant noting that it “plans to use a U.S. financial institution as an intermediary in converting the U.S. dollar payment received from [the unnamed party] into British Pounds”. Because the applicant’s bank must “use a U.S. financial institution as an intermediary in converting the U.S. dollar payment received…into British Pounds,” it is clear that the bank of the applicant is a non-U.S. bank that holds a dollar...