OFAC designated the Russian Federal State Budgetary Institution Marine Rescue Service ("MRS") to the Non-SDN Menu-Based Sanctions List ("NS-MBS List"). Concurrently, OFAC authorized certain transactions involving the MRS that are not related to the construction of the Nord Stream 2 pipeline, the TurkStream pipeline or any successor project to either pipeline, and that would otherwise be prohibited by the Protecting Europe's Energy Security Act of 2019 ("PEESA").
OFAC specified that General License ("GL") No. 1 does not authorize transactions involving any vessels of MRS or of any entity in which MRS owns, directly or indirectly, a 50 percent or greater interest that are identified as blocked property on OFAC's NS-MBS List.
In new FAQ 894, OFAC outlined the authority of GL No. 1. In new FAQ 895, OFAC clarified that persons sanctioned solely pursuant to PEESA are blocked, except for the importation of goods; however, entities sanctioned under both PEESA and another blocking authority appear on OFAC's List of Specially Designated Nationals and Blocked Persons List ("SDN List"), and transactions with such entities are not subject to the exception for the importation of goods.
OFAC also made related updates to its NS-MBS List and SDN List.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
