OFAC Sanctions Russian Subsidiary, Amends Venezuela-Related General Licenses, FAQs

The Treasury’s Office of Foreign Assets Control issued a Venezuela-related designation, amended three Venezuela-related general licenses and amended two frequently asked questions, according to a March 12 notice. The designation targets Switzerland-based TNK Trading International S.A. for operating in Venezuela’s oil sector. The company is a subsidiary of Russian state-controlled Rosneft Oil Company, according to a press release.

OFAC also issued amended General License No. 15C, which authorizes certain transactions with Banco de Venezuela for financial services companies; General License No. 16C, which authorizes the maintenance of U.S. accounts and noncommercial, personal remittances involving certain banks; and General License No. 36A, which authorizes certain transactions necessary to the wind-down of transactions with Rosneft and TNK Trading International.

In FAQ 817, OFAC clarified that General License 36A implements a wind-down period for transactions with TNK Trading International and any entity it owns by 50% or more. In FAQ 818, OFAC clarified that non-U.S. people may wind-down transactions with Rosneft or TNK Trading International without risk of sanctions violations if the activity is “consistent” with the general license and completed prior to 12:01 a.m. on May 20. OFAC also said “entering into new business” with either company is not considered wind-down activity.