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Clifford Chance

Clifford Chance


OFAC Dings Company for Delinquent Rosneft Payments in First Enforcement Action Under Directive 2, Executive Order 13662

26 April 2019

On April 25, 2019, OFAC announced a $75,375 settlement with US software provider Haverly Systems, the agency's first public enforcement of Directive 2 under Executive Order 13662 "Blocking Property of Additional Persons Contributing to the Situation in Ukraine." Under Directive 2, US persons are prohibited from transacting or otherwise dealing "in new debt of greater than 90 days maturity" of entities identified by OFAC on the Sectoral Sanctions Identification List. The definition of "debt" includes payment terms resulting in an extension of credit, such as a commercial invoice. Haverly allegedly violated Directive 2 when it received payments for invoices issued to JSC Rosneft more than 90 days after the invoice dates.

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