On Tuesday, OFAC added another question to its FAQ for the Ukraine-related sanctions program:
418. How does OFAC interpret the term “shale projects” with respect to the prohibitions in Directive 4 under Executive Order 13662?
The prohibitions in Directive 4 under Executive Order 13662 apply to deepwater, Arctic offshore, or shale projects with the potential to produce oil in the Russian Federation, or in maritime area claimed by the Russian Federation and extending from its territory. The term “shale projects” applies to projects that have the potential to produce oil from resources located in shale formations. Therefore, as long as the projects in question are neither deepwater nor Arctic offshore projects, the prohibitions in Directive 4 do not apply to exploration or production through shale to locate or extract crude oil (or gas) in reservoirs.
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