ANALYSIS: The US Treasury's Office of Foreign Assets Control
(OFAC) has imposed further sanctions on Russian individuals and
companies. These sanctions will have significant impact on
businesses, particularly those operating in the oil and gas
sector.
As of 6 April 2018, 24 Russian individuals and 14 Russian
companies have been added to the list of specially designated
nationals (SDNs). The newly-listed SDNs include large companies and
individuals with significant business interests.
US persons cannot do business with the SDNs or with any entity
that is owned 50% or more in aggregate by one or more SDNs. Non-US
persons could face sanctions for knowingly facilitating significant
transactions for or on behalf of the SDNs or with any entity that
is owned 50% or more in aggregate by one or more SDN - a notable
extension of the US sanctions regime to overseas persons and
businesses.