OFAC FAQ (Current) # 817 - Rosneft Trading S.A. and TNK Trading International S.A.

Date issued: Mar. 12 2020

TURBOFAC Commentary (165 words)

Notes:

1) The primary purpose of this FAQ is to clarify, for persons less familiar with the scope and operation of U.S. sanctions laws, that i) the blocking of Rosneft Trading S.A. does not necessarily result in the blocking of the parent company of Rosneft Trading S.A., and ii) that the Russia-related sectoral sanctions pursuant to which both Rosneft Trading S.A. and its parent are subject operate completely independent of the blocking of Rosneft Trading S.A. pursuant to EO 13850. The operation of the 50% rule and the concept of the independence of discrete sanctions programs can be tricky, but the FAQ does not provide any interpretive guidance that has not already been provided in other contexts.

2) FAQ amended on 12 March 2020 to account for the blocking of TNK Trading International S.A.

3) See generally Examples of Transactions Deemed to be, and not to be, Within the Scope of the Standard "Wind-down" and "Maintenance" GLs