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414. Does Directive 4 apply to projects that have the potential to produce gas?
If a deepwater, Arctic offshore, or shale project has the potential to produce oil, and the other requirements for either of the Directive 4 prohibitions are fully satisfied, then the relevant Directive 4 prohibition applies, irrespective of whether the project also has the potential to produce gas. If the project has the potential to produce gas only, then the Directive 4 prohibitions do not apply. [10-31-2017]
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414. Does Directive 4 apply to projects that have the potential to produce gas?
If a deepwater, Arctic offshore, or shale project in the Russian Federation, or in maritime area claimed by the Russian Federation and extending from its territory, and involving a person named under Directive 4 has the potential to produce oil, then the prohibition applies, irrespective of whether the project also has the potential to produce gas. If the project has the potential to produce gas only, then the prohibition does not apply. [9-12-2014]
1) Compare BIS' FAQs implementing the same provision of CAATSA:
https://www.bis.doc.gov/index.php/licensing/embassy-faq/cat/16-russia-sanctions