On 12 March 2020, OFAC designated Switzerland-based oil broker and Rosneft subsidiary TNK Trading International SA (“TNK Trading”) as a Specially Designated National (“SDN”) pursuant to Executive Order 13850 for operating in the oil sector of the Venezuelan economy. The action follows OFAC’s February 18, 2020 designation of another Rosneft subsidiary, Rosneft Trading SA (“Rosneft Trading”), and its president, who also were targeted for operating in Venezuela’s oil sector. Concurrently, OFAC issued an updated General License 36A authorizing U.S. persons to engage in certain transactions ordinarily incident and necessary to the wind down of transactions involving TNK Trading or Rosneft Trading, or any entity in which they own a 50% or greater interest, through May 20, 2020.
For more on this issue, see our February 18, 2020 IRC Blog post on the implications of OFAC’s designation of Rosneft Trading.