Today, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) imposed sanctions on Rosneft Trading S.A., a Switzerland-based subsidiary of Russian state-controlled global energy company Rosneft Oil, and its president and board executive Didier Casimiro. Specifically, OFAC designated the company as a specially designated national (SDN) pursuant to Executive Order (E.O.) 13850 for supporting the Maduro regime by brokering the sale and transport of Venezuelan crude oil in circumvention of U.S. sanctions laws. OFAC designated Casimiro as an SDN for acting on behalf of Rosneft Trading S.A. in collaborating with Petróleos de Venezuela (PdVSA), the designated Venezuelan state-owned oil company, on projects between Rosneft Trading S.A. and PdVSA. Rosneft Trading S.A., as well as parent Rosneft Oil Company, were previously subject to restrictions under Ukraine/Russia related Directives 2 and 4 for operating in the energy sector of the Russia Federation.
Along with the designations, OFAC also issued General License (GL) 36 authorizing U.S. persons to engage in certain activities necessary to wind down transactions involving Rosneft Trading S.A., or any entity in which the company owns, directly or indirectly, a 50% or greater interest, through 12:01 a.m. eastern daylight time, May 20, 2020.
After the GL 36 expires, unless exempt or otherwise authorized by OFAC, U.S. persons will no longer be able to engage in transactions with Rosneft Trading S.A., or any entity in which Rosneft Trading S.A. owns, directly or indirectly, a 50 percent or greater interest, and must block property or interests in property of Rosneft Trading S.A. that are in the United States or the possession or control of a U.S. person. Blocked transactions will also be subject to OFAC reporting requirements.