On August 2, President Trump signed new legislation which will impose new sanctions on Arctic offshore, deepwater or shale oil drilling projects which are partially owned by certain sanctioned Russian energy companies. Previously, these sanctions only applied if the sanctioned Russian companies owned greater than a 50% ownership interest in the project and if the projects were also located within the Russian federation. Now, the sanctions will apply to “new” offshore, deepwater or shale projects in which the sanctioned companies own as little as a 33% interest and will also apply to projects located both inside and outside of the Russian federation. The United States Department of Treasury’s Office of Foreign Assets Control (“OFAC”) is required to issue new rules implementing these changes within 90 days. A detailed review of the new legislation, which also includes sanctions against North Korea and Iran, can be found on our TMT Industry Insider blog.