OFAC designated TNK Trading International S.A. ("TTI") for "operating in the oil sector of Venezuela." OFAC also amended several general licenses and two FAQs.
OFAC stated that TTI is a subsidiary of the U.S.-designated Rosneft Trading S.A. As previously covered, Rosneft Trading S.A. was designated by OFAC for conducting operations in the oil sector of the Venezuelan economy in violation of Executive Order 13850 ("Blocking Property of Additional Persons Contributing to the Situation in Venezuela").
OFAC designated TTI after Rosneft Trading S.A. changed the allocation of cargoes of Venezuelan oil to TTI in order to evade OFAC sanctions.
In addition, OFAC updated several general licenses, including:
- General License 15C, which replaces General License 15B, authorizes MasterCard Inc., Visa Inc., American Express Company, Western Union Company, and MoneyGram International to continue activities with certain Venezuelan banking entities.
- General License 16C, which replaces General License 16B, authorizes the maintenance of U.S. citizens' accounts and noncommercial, personal remittances involving certain Venezuelan-based banks.
- General License 36A, which replaces General License 36, allows U.S. persons to conduct certain transactions involving TTI that are necessary to wind down transactions with TTI.
OFAC also updated FAQ 817, to explain that the imposition of sanctions on Rosneft Trading S.A., and now TTI, does not extend to both companies' ultimate parent, Open Joint Stock Company Rosneft Oil Company, or any other Rosneft entities that are not owned at least 50 percent or more in the aggregate by Rosneft Trading S.A., TTI, and/or other blocked persons. Similarly, OFAC updated FAQ 818 to explain the authorization for certain activities permitted by General License 36A.
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