OFAC May Issue Wind-Down Exceptions for Nord Stream 2 Sanctions

The Treasury’s Office of Foreign Assets Control issued a frequently asked question to address Congress’ inclusion of sanctions on the Nord Stream 2 pipeline in the 2020 National Defense Authorization Act (see 1912190075), according to a Dec. 20 notice. In FAQ 815, OFAC clarified the wind-down provisions in the NDAA, which specify that all parties involved in selling, leasing or providing vessels for Nord Stream 2 or Turkstream must “immediately cease construction-related activity.” But OFAC said it may extend “good-faith wind-down exceptions” to certain parties for the safety of the pipeline, the crews and to avoid environmental damage.