The Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury has announced new extensive sanctions against the oil and gas sector of the Russian economy, targeting vertically integrated oil companies (VINC), specific project operators in resource extraction, shipping, insurance and service companies, and top management.
Notably, these anti-Russian sanctions are the first to be imposed on so-called vertically integrated oil companies—structures that encompass enterprises covering all stages of the technological process in oil and gas operations, from resource extraction and processing to the sale of end products.
The sanctions include the addition of PJSC Gazprom Neft and PJSC Surgutneftegas to the Specially Designated Nationals (SDN) List.
The restrictions apply not only to the parent companies but also to the majority of their subsidiaries, including: Gazpromneft-Moscow Refinery, Gazpromneft Omsk Refinery, Gazpromneft Shelf, Gazpromneft Aero, Gazpromneft Bitumen Materials, Gazpromneft Khantos, Gazpromneft Lubricants Ltd, Gazpromneft Noyabrsk, Gazpromneft Orenburg, Gazpromneft Technological Partnerships, Gazpromneft Vostok, Gazpromneft Yamal, Gazpromneft Zapolyarnoye, Gazpromneft Regional Sales, Gazpromneft Tajikistan, Gazprom Neft International SA, Gazpromneft Kazakhstan, Gazprom Neft Asia (Kyrgyzstan), Munay Myrza (Kyrgyzstan), KINEF, Kaliningradnefteprodukt, Kirishiavtoservice, Lengiproneftekhim, Novgorodnefteprodukt, Pskovnefteprodukt, Tvernefteprodukt, and Surgutneftegasbank.
Subsidiaries of PJSC Gazprom Neft in Serbia, Bulgaria, Romania, Bosnia and Herzegovina, Kyrgyzstan, and Kazakhstan have also been included in the SDN List.
The United Kingdom has joined the U.S. sanctions against PJSC Gazprom Neft and PJSC Surgutneftegas.
A deadline of February 27, 2025, has been set for divesting from the securities of the mentioned companies and ceasing any commercial contacts with them.
Sanctions have also been imposed on oil and gas operators: RN-Vankor, Rusgazalyans, and UDS Neft. Sanctions have been placed on Gazprom Shelf Project JSC, as well as Achimgaz JSC and Laya Vozhnegaz LLC.
In addition to oil and gas operators, companies involved in insuring tankers transporting Russian oil products, such as Ingosstrakh and AlfaStrakhovanie, have also been sanctioned.
The U.S. has imposed extensive sanctions on vessels belonging to Sofcomflot, Gazpromneft Marine Bunker, Rosnefteflot, Argo Tanker Group, Sunor, RPK Nord, LK Volga, and other shipping companies.
Sanctions have also been extended to foreign traders from the UAE and Hong Kong: Black Pearl Energy Trading LLC (Black Pearl), Arctos Shipping And Trade DMCC, Demex Trading Limited DMCC, Eterra Crude Oil Abroad Trading LLC, Marion Commodity DMCC, Marsa Energy Trading DMCC, Pratum Oil Trading LLC, Zion Trade Limited, Guron Trading Limited, Sunrise X Trading Co, and others, along with numerous oil service companies.
Concurrently with the implementation of new sanctions, OFAC has shortened the duration of the license allowing sanctioned Russian banks to conduct settlement operations related to the energy sector. The relevant license, which applies to Sberbank, VTB, Alfa-Bank, and several other banks, will be valid until March 12, 2025, instead of April 30, 2025.
The law firm "Nadmitov, Ivanov and Partners" provides consultation on sanctions and Russian counter-sanctions.
Email: info@nplaw.ru
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