On Friday, September 12, EU and USA entered into force additional round of sanctions against Russia. New sanctions include restrictive measures targeting the largest Russian oil and gas companies.
EU
However, such prohibitions will not apply to the execution of an obligation arising from a contract or a framework agreement concluded before 12 September 2014 or ancillary contracts necessary for the execution of such contracts.
Besides, the prohibition shall not apply where the services in question are necessary for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health and safety or the environment.
Sanctions of the European Union also include the prohibition for providing investment services for the largest Russian oil and gas companies, namely Rosneft, Transneft, Gazpromneft. The restrictions cover investment services for or assistance in the issuance of transferable securities and money-market instruments with a maturity exceeding 30 days, issued after 12 September 2014.
US
According to the directive of OFAC, the provision, exportation, or reexportation of goods, services (except for financial services), or technology in support of exploration or production for deepwater, Arctic offshore, or shale projects that have the potential to produce oil in the Russian Federation, or in maritime area claimed by the Russian Federation and extending from its territory
US sanctions target not only future projects and transactions, but also existing project of US companies in Russian Federation.
The prohibitions do not apply to gas projects, however in case if the project produce gas AND oil from deepwater, Arctic offshore, or shale formations, then it is covered by the sanctions.
US sanctions also foresee the prohibitions of providing financial support or loans for the listed Russian oil and gas companies for the period longer than 90 days.
Additional sanctions enforced by EU and US could make the realization of announced large oil extraction project in Russia more complicated due to the lack of domestic financial and technological resources. Such promising developments like joint project of ExxonMobil and Rosneft on Arctic shelf, joint projects of BP and Rosneft and Shell and Gaspromneft for shale oil extraction could also suffer from the applied restrictive measures.
One of the largest of such projects under threat is the joint activity of ExxonMobil and Rosneft on the Cara Sea. On 9 of August, 2014 joint enterprise Carmorneftegas
The lawyers of oil and gas companies will thoroughly study the potential consequences of the announced sanctions against Russian companies, however
US Office of Foreign Assets Control in his
Strengthening of the restriction measures was put into effect at a time of falling oil prices. On September 15, the Brent oil was traded