US re-imposes sanctions on certain entities involved in Nord Stream 2. (Credit: Johannes Rupf from Pixabay)

The Department is imposing sanctions on a number of entities previously sanctioned pursuant to the Protecting Europe’s Energy Security Act (PEESA), as amended, for involvement in the construction of the Nord Stream 2 pipeline, as well as several new owners of vessels previously blocked pursuant to PEESA.      

All targets are being sanctioned pursuant to Executive Order (E.O.) 14024, which authorizes sanctions with respect to specified harmful foreign activities of the Government of the Russian Federation. 

ENTITIES AND AN INDIVIDUAL INVOLVED IN NORD STREAM 2 CONSTRUCTION 

Pursuant to section 1(a)(i) of E.O. 14024, the following entities are being designated for operating or having operated in the marine sector of the Russian Federation economy: 

  • SAMARA HEAT AND ENERGY PROPERTY FUND (SAMARA) is a Russia-based marine services entity that was previously designated under PEESA. 
  • JOINT STOCK COMPANY NOBILITY (NOBILITY) is a Russia-based marine services entity that was previously designated pursuant to PEESA.   
  • LIMITED LIABILITY COMPANY KOKSOKHIMTRANS (KOKSOKHIMTRANS) is a Russia-based water transport logistics entity that was previously designated pursuant to PEESA.   
  • JOINT STOCK COMPANY ARDAL (ARDAL) is a Russia-based marine services entity that acquired two vessels which were previously identified as property pursuant to PEESA. 
  • LIMITED LIABILITY COMPANY FARVATER (FARVATER) is a Russia-based marine services entity that acquired a vessel previously identified as blocked property pursuant to PEESA.   
  • KVT RUS (KVT RUS) is a Russia-based water transport entity that was previously designated pursuant to both PEESA and Section 232 of the Countering America’s Adversaries Through Sanctions Act (CAATSA).   
  • LIMITED LIABILITY COMPANY MORTRANSSERVICE (MORTRANSSERVICE) is a Russia-based marine services entity that was previously designated pursuant to PEESA.   
  • FEDERAL STATE BUDGETARY INSTITUTION MARINE RESCUE SERVICE (MARINE RESCUE SERVICE) is Russia’s state-owned maritime rescue service that was designated pursuant to PEESA for its involvement in service provision to Russian vessels constructing the Nord Stream 2 pipeline.    

AKADEMIK CHERSKIY is a vessel being identified as property in which SAMARA has an interest.  AKADEMIK CHERSKIY is managed by SAMARA and was previously identified as property of Samara pursuant to PEESA.  

IVAN SIDORENKO and OSTAP SHEREMETA are vessels being identified as property in which NOBILITY has an interest.  They are both vessels owned by NOBILITY and were previously identified as property of NOBILITY pursuant to PEESA. 

ANTEY and HERMES are vessels being identified as property in which ARDAL has an interest.  ANTEY and HERMES are both vessels owned by ARDAL and were previously identified as property under PEESA. 

LAMANTIN is a vessel being identified as property in which FARVATER has an interest.  LAMANTIN is owned by FARVATER and was previously identified as property pursuant to PEESA. 

FIONA is a vessel being identified as property in which KVT RUS has an interest.  FIONA is owned by KVT RUS and was previously identified as property pursuant to PEESA and CAATSA. 

The following ten vessels are being identified as property in which MARINE RESCUE SERVICE has an interest:  

  • ARTEMIS OFFSHORE is a vessel which was previously identified as property pursuant to PEESA.  ARTEMIS OFFSHORE is owned and managed by MARINE RESCUE SERVICE. 
  • BAKHTEMIR is a vessel which was previously identified as property pursuant to PEESA.  BAKHTEMIR is managed by MARINE RESCUE SERVICE. 
  • BALTIYSKIY ISSLEDOVATEL is a vessel which was previously identified as property pursuant to PEESA.  BALTIYSKIY ISSLEDOVATEL is managed by MARINE RESCUE SERVICE. 
  • FINVAL is a vessel which was previously identified as property pursuant to PEESA.  FINVAL is owned by MARINE RESCUE SERVICE. 
  • KAPITAN BEKLEMISHEV is a vessel which was previously identified as property pursuant to PEESA.  KAPITAN BEKLEMISHEV is managed by MARINE RESCUE SERVICE. 
  • MURMAN is a vessel which was previously identified as property pursuant to PEESA.  MURMAN is managed by MARINE RESCUE SERVICE. 
  • NARVAL is a vessel which was previously identified as property pursuant to PEESA.  NARVAL is owned and managed by MARINE RESCUE SERVICE. 
  • SIVUCH is a vessel which was previously identified as property pursuant to PEESA.  SIVUCH is owned and managed by MARINE RESCUE SERVICE. 
  • SPASATEL KAREV is a vessel which was previously identified as property pursuant to PEESA.  SPASATEL KAREV is managed by MARINE RESCUE SERVICE. 
  • UMKA is a vessel which was previously identified as property pursuant to PEESA.  UMKA is owned and managed by MARINE RESCUE SERVICE. 

Pursuant to section 1(a)(i) of E.O. 14024, the following entity and individual are being designated for operating or having operated in the technology sector of the Russian Federation economy: 

  • OBSHCHESTVO S OGRANICHENNOI OTVETSTVENNOSTYU MTV (OOO MTV) is a Russia-based technology entity founded by U.S.-designated MATTHIAS ARTHUR WARNIG.   
  • MATTHIAS WARNIG (WARNIG) is the founder of OOO MTV and the former CEO of NORD STREAM 2 AG.  WARNIG was previously designated pursuant to PEESA.   

Pursuant to section 1(a)(vii) of E.O. 14024, the following entity is being designated for being owned or controlled by, or having acted or purported to act for on behalf of, directly or indirectly, the Government of the Russian Federation: 

  • NORD STREAM 2 AG is the operator of the Nord Stream 2 pipeline project that was previously designated pursuant to PEESA.   

Pursuant to section 1(a)(i) of E.O. 14024, the following entity is being designated for operating or having operated in the financial services sector of the Russian Federation economy: 

  • LIMITED LIABILITY COMPANY RNCB INSURANCE is a Russia-based insurance provider that was previously designated pursuant to PEESA for providing insurance to companies involved in the Nord Stream 2 project.     

SANCTIONS IMPLICATIONS 

As a result of today’s sanctions-related actions, and in accordance with E.O. 14024, as amended, all property and interests in property of the sanctioned persons described above that are in the United States or in possession or control of U.S. persons are blocked and must be reported to the Department of Treasury’s Office of Foreign Assets Control (OFAC). Additionally, all individuals or entities that have ownership, either directly or indirectly, 50 percent or more by one or more blocked persons are also blocked.  

All transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons are prohibited unless authorized by a general or specific license issued by OFAC or exempt.  These prohibitions include any contribution or provision of funds, goods, or services by, to, or for the benefit of any blocked person and the receipt of any contribution or provision of funds, goods, or services from any such person. 

The power and integrity of U.S. government sanctions derive not only from the U.S. government’s ability to designate and add persons to the SDN List, but also from its willingness to remove persons from the SDN List consistent with the law. The ultimate goal of sanctions is not to punish, but to bring about a positive change in behavior.