OFAC FAQ #414 · Ukraine-/Russia-related Sanctions
Does Directive 4 apply to projects that have the potential to produce gas?
OFAC's answer
If a deepwater, Arctic offshore, or shale project has the potential to produce oil, and the other requirements for either of the Directive 4 prohibitions are fully satisfied, then the relevant Directive 4 prohibition applies, irrespective of whether the project also has the potential to produce gas. If the project has the potential to produce gas only, then the [Directive 4](https://ofac.treasury.gov/media/8716/download?inline) prohibitions do not apply.