OFAC FAQ #536 · Ukraine-/Russia-related Sanctions
For purposes of subsection 2 of Directive 4, what does it mean for a project to be “initiated”?
OFAC's answer
For purposes of subsection 2 of [Directive 4](https://ofac.treasury.gov/media/8716/download?inline), a project is “initiated” when a government or any of its political subdivisions, agencies, or instrumentalities (including any entity owned or controlled directly or indirectly by any of the foregoing) formally grants exploration, development, or production rights to any party.