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OFAC Sanctions Rosneft's Swiss Trading Arm for Operating in Venezuela's Oil Sector

February 20, 2020
Firm Memoranda

On Tuesday, February 18, 2020, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) designated Rosneft Trading S.A., the Swiss trading arm of Russia's state-controlled oil company, and its chairman of the board of directors and president, Didier Casimiro, to the Specially Designated Nationals And Blocked Persons (SDN) List. As a result, U.S. persons are prohibited from engaging in transactions or otherwise dealing with Rosneft Trading, Casimiro, or any entities in which they hold, directly or indirectly, a 50 percent or more interest. Additionally, all of their property and interests in property that are in the United States or in the possession or control of U.S. persons, are blocked and must be reported to OFAC. Concurrent with these designations, OFAC issued a general license providing a 90-day window to engage in certain activities necessary to wind down business with Rosneft Trading.

OFAC's action also has important implications for non-U.S. persons, as it signals a clear willingness to impose sanctions on anyone operating in the Venezuelan oil sector or otherwise supporting the Maduro regime.

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If you have any questions about the issues addressed in this memorandum, or if you would like a copy of any of the materials mentioned in it, please do not hesitate to reach out to:

William Burck
Phone: 202-538-8120

Stephen Hauss
Phone: 202-538-8111