On 18 February 2020, OFAC designated the Switzerland-based oil broker Rosneft Trading SA (“Rosneft Trading”), a subsidiary of Rosneft Oil Company, and its president Didier Casimiro, as Specially Designated Nationals (“SDN’s”) for “operating in the oil sector of the Venezuelan economy,” under Executive Order 13850.
These designations do not change the status of the parent entity Rosneft Oil, which remains on the SSI List.
For current business partners of Rosneft Trading, OFAC has issued a General License, No 36, which authorises until 20 May 2020 “all transactions and activities prohibited by” Executive Order 13850 “that are ordinarily incident and necessary to the wind down of transactions involving Rosneft Trading S.A., or any entity in which Rosneft Trading S.A. owns, directly or indirectly, a 50 percent or greater interest.”
In addition to the 20 May termination date, this general license does not authorise “[a]ny debit to an account of Rosneft Trading S.A., or any entity in which Rosneft Trading S.A. owns, directly or indirectly, a 50 percent or greater interest, on the books of a U.S. financial institution,” or any other transactions that are prohibited by OFAC.
That said, the designation of Didier Casimiro as an SDN should stay on the radar of any company considering to engage in business with him, or any of the entities that he may arguably control. In addition to serving as Rosneft Trading’s president, Casimiro is a member of Rosneft Oil’s Executive Management Board as the Vice President of Refining, Petrochemical, Commerce and Logistics. Casimiro does not own or currently hold a dominant minority interest in Rosneft Oil. Casimiro is also the Chairman of the Board of Directors for the following entities:
- PJSC Saratov Refinery;
- Rosneft – MP Nefteprodukt;
- CJSC Rosneft-Armenia;
- LLC RN-Yerevan;
- LLC RN-Commerce; and
- LLC RN-Refining.
Furthermore, Casimero is also the Chairman of the Supervisory Board at PRJSC LINIK, and member of the Board of Directors at OJSC NGK Slavneft, OJSC NGK Slavneft-YANOS, Rosneft Global Trade S.A., JSC SPIMEX, Rosneft Techno S.A., PJSOC Bashneft, LLC RN-Foreign Projects, Nayara Energy Limited, and SIA ITERA Latvija.