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Author: Robert Ward

US Sanctions Squeeze China and Russia Over Their Support to North Korea

On August 22, 2017, the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed a new round of designations targeting certain Chinese and Russian entities and individuals for their North Korean activities.  This unilateral step comes just a couple of weeks after the United Nations Security Council, backed by China and Russia, imposed strict new sanctions on North Korea in the wake of its testing of two functional intercontinental ballistic missiles (ICBMs).  Further, this comes on the heels of the ensuing threats of war between President Donald J. Trump and North Korean dictator Kim Jung Un.   There appears to be no question that the U.S. administration perceives the North Korean threat to be imminent, requiring swift action against those supporting the rogue regime. Specifically, OFAC’s action is the result of findings that the following entities and individuals have been involved in supporting North Korea’s nuclear missile development program: The following entities have been added to OFAC’s SDN List: DANDONG RICH EARTH TRADING CO., LTD., Jiadi Square, Number 64, Binjiang Middle Road, Room 1001, Building B, Dandong City, Liaoning, China [NPWMD] (Linked To: KOREA KUMSAN TRADING CORPORATION). DANDONG TIANFU TRADE CO., LTD. (Chinese Simplified: 丹东天富贸易有限公司), No. 5, Shiwei Road, Zhenxing District, Dandong City, China [DPRK3]. DANDONG ZHICHENG METALLIC MATERIAL CO., LTD. (Chinese Simplified: 丹东至诚金属材料有限公司) (a.k.a. DANDONG CHENGTAI; a.k.a. DANDONG CHISONG METAL MATERIALS COMPANY; a.k.a. DANDONG...

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The Impact of the “Countering America’s Adversaries Through Sanctions Act” on the Oil and Gas Industry

The recently enacted “Countering America’s Adversaries Through Sanctions Act” (hereafter “the Act”) bodes rather significant changes for the Oil and Gas Industry. The changes arise from the Russian Sanctions and the Ukrainian crisis.  A review of the initial Executive Order 13662 from September 14, 2014 (Directive 4) versus the provisions of the Act will readily reveal what changes will be in store. Executive Order 13662 “. . . the following activities by a U.S. person or within the United States are prohibited, except to the extent provided by law or unless licensed or otherwise authorized by the Office of Foreign Assets Control: the provision, exportation, or reexportation, directly or indirectly, 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 areas claimed by the Russian Federation and extending from its territory, . . . “[Italics emphasis added]. The Act “. . . the directive prohibits the provision, exportation, or reexportation, directly or indirectly, by United States persons or persons within the United States, of goods, services (except for financial services), or technology in support of exploration or production for new deepwater, Arctic offshore, or shale projects— (1) that have the potential to produce oil; [Italics emphasis added]. Comment The Act no longer limits...

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