The Office of Foreign Assets Control of the US Department of the Treasury has designated Rosneft Trading S.A., a Swiss oil brokerage firm that is a subsidiary of the Russian state-controlled energy company, Rosneft Oil Company. OFAC also designated Didier Casimiro, a Russian national who serves as chairman of the board of directors and president of Rosneft Trading. The designations, made pursuant to Executive Order 13850, as amended, relate to the company’s involvement in the Venezuelan oil sector. According to OFAC, between September 2019 and January 2020, Rosneft Trading facilitated shipments of millions of barrels of Merey-16 crude oil from Venezuela to Asia and West Africa. Both Rosneft Trading S.A. and its parent company were already subject to certain restrictions under Ukraine- and Russia-related Directives 2 and 4.
In a related action, OFAC has issued General License No. 36 pursuant to the Venezuela Sanctions Regulations, 31 CFR Part 591. The new general license authorizes certain activities necessary to the wind-down of transactions involving Rosneft Trading S.A. and its subsidiaries. The general license authorizes such activity through May 19, 2020, but does not allow debits to Rosneft Trading accounts or those of its subsidiaries.
OFAC also issued new Venezuela-related frequently asked questions, which explain that US persons will be prohibited from engaging in transactions with Rosneft Trading after expiration of General License 36, and non-US persons may wind down transactions with Rosneft and its subsidiaries without exposure to sanctions under Executive Order 13850 until the May 2020 expiration date, provided that such activities do not constitute new business, and are consistent with G.L. 36.