Against the Russian Energy Sector.
By Bracewell
On January 10, 2025, in a final action to, among other things, deter Russian aggression on the international stage, the US Department of the Treasury enacted sweeping new sanctions on the Russian energy sector. Specifically, the sanctions package includes:
- Determination authorizing sanctions on any person to operate or have operated in Russia’s energy sector;
- Determination banning provision of US petroleum services to Russia and
- Imposition of blocking sanctions against major players in the oil and gas markets, vessels in the so-called “shadow fleet,†certain traders of Russian oil, Russian maritime insurers and Russian oilfield service providers.
Below we explain these actions and how they substantially increase the sanctions risks associated with Russian energy both for and beyond the directly impacted entities, as well as the General Licenses (GLs) that accompany the sanctions.
Russian Sanctions Regime Overview
On April 15, 2021, President Biden issued Executive Order (E.O.) 14024, “Blocking Property With Respect To Specified Harmful Foreign Activities of the Government of the Russian Federation,†which established a national emergency by which Treasury’s Office of Foreign Asset Controls (OFAC) could impose sanctions against individuals and entities furthering specified harmful foreign activities of Russia, with a focus on national security. This national emergency is separate from that related to the crisis in Ukraine, which is addressed in E.O. 13660 and its progeny.
Related People
