SANCTIONS AGAINST RUSSIANS LOOPHOLES

In spite of sanctions against Russia, it’s back to business again.

Under sanctions, the U.S. Treasury definition of ‘U.S. persons’ does not include ‘foreign incorporated subsidiaries of U.S. companies’. This leaves open the possibility of American business links with SSS (Sectoral Sanctions Identifications-listed firms) through foreign subsidiaries. In the EU, EU sanctions prohibit EU entities from direct provision of oil and gas services but do not specifically address technology transfer.

So there you have it: