March, 2020 Another Rosneft-related entity added to the SDN list

Another Rosneft-related entity added to the SDN list

On 12th March, 2020, OFAC designated TNK Trading International S.A. (“TTI”) to the Specially Designated Nationals (SDN) list under E.O. 13850 for operating in the oil sector of the Venezuelan economy. TTI was also designated to the Sectoral Sanctions Identifications (SSI) list under E.O. 13662 dealing with the Ukraine.

It appears that the designation of TTI is intended to impact all transactions with that entity, not just transactions concerning Venezuela, and will affect both US and non-US entities, so Members should consider taking legal advice before entering into, or continuing, any transactions with TTI. The implications of the designation are explained in more detail here https://www.freehill.com/wp-content/uploads/2020/03/NYDOCS1-522645-v1-Client_Alert_on_TNK_Trading.pdf