The US Office of Foreign Assets Control ("OFAC") has implemented extensive new sectoral sanctions in response to the situation in Ukraine and added additional entities to the Specially Designated Nationals ("SDN") list. In summary, the new measures:
- Update and add to the entities in the Sectoral Sanctions Identification List ("SSI List") under Directive 1 (applicable to certain financial institutions) and reduce the tenor of permissible financing and dealings in new debt to 30 days or fewer, from 90 days or fewer for persons subject to Directive 1.
- Update and add to the entities in the SSI List under Directive 2 (applicable to certain companies in the energy sector).
- Create a new prohibition against financing persons in the SSI List under a newly announced Directive 3. These entities are largely defense-related companies.
- Create a new prohibition against the provision of goods, services (other than financial services) or technology in support of certain deepwater, Arctic offshore or shale products which could produce oil for Russia and which involved specified companies listed in new Directive 4.
To read more about the measures from our team in New York, click here.
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