Hong Kong

Unit 601, 6/F of Mill 5 of the Mills, 45 Pak Tin Par Street, Hong Kong, China

3000934, Registration Number

Hong Kong-based Bellatrix Energy Limited (Bellatrix) has sharply increased its share of the trade of Russian oil since the price cap policy was implemented. Since the middle of June 2023 alone, vessels chartered by Bellatrix have made more than 150 port calls in Russia. Since Russia’s full-scale invasion of Ukraine, Bellatrix has traded tens of millions of tons of crude oil and other products of Russian state-owned oil companies and has received a loan worth hundreds of millions of dollars from a Russian state-owned bank. Bellatrix has also borrowed from Joint Stock Company Russian Regional Development Bank, which OFAC designated on November 2, 2023. Bellatrix, Covart, and Voliton were designated pursuant to E.O. 14024 for operating or having operated in the marine sector of the Russian Federation economy. The Sanar 15 was identified as property in which Covart has an interest.

https://home.treasury.gov/news/press-releases/jy2008

2023-12-20

US

Executive Order 14024 of April 15, 2021 Blocking Property With Respect To Specified Harmful Foreign Activities of the Government of the Russian Federation

OFAC country specific

Russia

Blocking Property, Suspending Entry, Trade sanctions

• https://ofac.treasury.gov/faqs/1127 • https://ofac.treasury.gov/faqs/1029

In response to the Russian Federation’s continued use of its military-industrial base to support its aggression against Ukraine, the President has issued an Executive Order (E.O.) amending E.O. 14024 that provides the Office of Foreign Assets Control (OFAC) with new authorities to target foreign financial institutions for engaging in certain transactions. Foreign financial institutions that conduct or facilitate significant transactions or provide any service involving Russia’s military-industrial base run the risk of being sanctioned by OFAC. The United States and partners have put in place a sanctions and export controls regime that has severely restricted Russia’s ability to import many of the items that directly support its brutal and unjustified war against Ukraine. As a result, Russia is increasingly using third countries to evade sanctions and continue its procurement of certain critical items. The United States and partners have published multiple advisories, including detailed red flags, to warn the private sector about Russian sanctions evasion in support of its war machine and to support compliance efforts. OFAC’s new targeting authorities, which are aimed at foreign financial institutions that provide services to, or engage in significant transactions relating to, Russia’s military-industrial base, come as a natural evolution of OFAC’s work to counter evasion and hold accountable those perpetuating Russia’s war against Ukraine, including financial facilitators. OFAC is issuing this advisory to provide guidance to foreign financial institutions on the amendments to E.O. 14024, including practical guidance on how to identify sanctions risks and implement corresponding controls. For additional guidance on this E.O., please see FAQs 1146–1157.

SDN / NS-MBS / CAPTA