Are Russia sanctions Myth or Reality?

Is it legal for US/UK company / national to sign service contract or supply products / goods to Russian Oil and Gas company?

The short answer is "yes", except “project based sanctions”, which are rare & selective.

There are 4 types of sanctions by the US & EU against Russian companies or individuals. Please note in theory only US or EU companies/individuals are subject to these sanctions.

1. Company based – list of military or Crimea companies or list of “oligarch” related companies (part of SDN list)

2. Persons based – list of “oligarchs”, government “officials”, “cronies” (SDN list) who is not allowed to sign contracts with

3. Finance based - no loans longer than 14 days are allowed for those on the list (SSI list and full SDN list)

4. Project based - the restricted projects are ones that meet all 4 factors happen simultaneously

“1) Oil + 2) Upstream + 3) Offshore + 4) Arctic or Deepwater / Shale” (SSI list)

Notes:the current sanctions actually effects 1% of Russian oil production: Prirazlomnaya and Novoportovskaya

Would you agree with above? Please share your comments & thoughts

P.S. Regulations:

OFAC, E.O.13662, Directives 1,2 & 4. OFAC, SDN List Update of April 28, 2014. OFAC, E.O.13662, Directive 1 (as amended on September 29, 2017) & Directive 4 (as amended on October 31, 2017). OFAC, Sectorial Sanctions Identification List of April 6, 2018.FAC, E.O.13662, Directive 4 (as amended on October 31, 2017).Dpt of Commerce, Bureau of Industry and Security, Billing Code 3510-33-P Regulation (EU) N 833/2014

Government links:

· US Search engine https://sanctionssearch.ofac.treas.gov

· UK: https://www.gov.uk/government/news/doing-business-in-russia-and-ukraine-sanctions-latest