Sanctions Risk22 Jan 2023 21:21
Interesting snippet from the Admissions Doc on the sanctions risk for AET. this may be the reason for the low price and may perhaps be the cause of a discount to the SP going forward even when the deals are signed:
Sanctions and bribery/corruption related risks
NIS holds a 4% interest in Block 3/05. Gazprom Neft holds 56.15% of NIS’ share capital. Gazprom
Neft is currently subject to US, EU and UK sanctions. Whilst the sanctions risk for the Company
proceeding is assessed to be low for a number of reasons, there is a risk that Gazprom Neft (along
with other Russian entities) may be the subject of additional sanctions in the future, including
potentially being made the subject of an asset freeze which would prevent any dealings with them.
If Gazprom Neft was made the subject of an asset freeze, any company which Gazprom Neft had a
50% or greater holding in or over which it exercised control would also effectively be sanctioned.
With respect to Block 3/05, any asset freeze imposed against Gazprom Neft would mean that NIS would effectively be sanctioned (due to Gazprom Neft having a 56.15% stake in NIS) and NIS’ shareholding in Block 3/05 (amounting to 4%) would be frozen and could not be sold. As NIS only has a 4% interest in Block 3/05, the Block itself would not be sanctioned, however, there could be practical problems in that some suppliers may refuse to supply equipment for use on the Block, some counterparties may refuse to buy oil from Block 3/05 due to the connection with Gazprom
Neft, and banks may be concerned about processing payments connected with Block 3/05. These would be decisions based on risk appetite rather than the application of sanctions and the Company anticipates the challenges would be capable of being navigated and managed.
Sonangol reportedly holds 20% of the share capital of an indirect subsidiary of PdVSA. PdVSA is
currently subject to US sanctions. As such, Sonangol appears to have an interest in a company
(PV) that is blocked by US sanctions. This does not mean that Sonangol is blocked (or sanctioned).
It could nevertheless create indirect sanctions risk if Sonangol were to breach US sanctions in its
conduct relating to PdVSA and OFAC were to decide to take action again Sonangol. The Company
has adopted extra precautions to ensure that Sonangol is not sanctioned at any time when the
Company transacts with Sonangol.
Sonangol EP (the owner of Sonangol) has been subject to corruption allegations for decades, with
government officials and high ranking Sonangol EP employees alleged to have benefitted from
Sonangol EP’s seemingly opaque financial reporting, transactions in which there were suspected
conflicts of interest and the alleged direct misappropriation of funds from Sonangol EP.