News 19 Feb, 2020 Venezuelan Sanctions - designation of Rosneft Trading S.A. Tony Paulson Head of Asia & Corporate Director On 18 February 2020, OFAC designated Rosneft Trading S.A. (“Rosneft Trading”) to the SDN List pursuant to Executive Order 13850 for operating in the oil sector of the Venezuelan economy. OFAC also designated to the SDN List Didier Casimiro, Rosneft Trading’s Vice President for Refining, Petrochemical, Commerce and Logistics. Mr. Casimiro was designated for acting or purporting to act on behalf of Rosneft Trading. Download PDF Simultaneously OFAC issued General Licence 36 which authorises ““all transactions and activities…that are ordinarily incident and necessary to the wind down of transactions involving Rosneft Trading S.A., or any entity in which Rosneft Trading S.A. owns, directly or indirectly, a 50 percent or greater interest…through 12:01 a.m. eastern daylight time, May 20, 2020.” Additional FAQs were also issued aimed at providing some clarity around these designations. FAQ 817 makes clear that the sanctions only apply to Rosneft Trading and not to its parent Open Joint-Stock Company Rosneft Oil Company or any subsidiary or affiliate which is not more than 50% owned by the designated entities. It should be noted however that both Rosneft Trading and Rosneft Oil Company are separately subject to U.S. Sectorial Sanctions imposed against Russia under Executive Order 13662 and it remains prohibited to provide both entities with certain services primarily related to debt finance. FAQ 818 clarifies the operation of General Licence 36 with regard to both U.S. and non-U.S. persons, stipulating that both are subject to the wind-down period in effect until 20 May 2020 and that new business not in place before 18 February 2020 will not be considered as wind-down activity. The Club’s U.S. attorneys Freehill Hogan & Mahar have produced a helpful Client Alert which sets out in detail the impact of these new designations. The effect on Members