Earlier today, President Obama signed an Executive Order (E.O.) expanding on E.O. 13660, which was issued on March 10, 2014. In addition to naming specific persons subject to the restrictions of E.O. 13660, including former Ukrainian President Viktor Yanukovych, the new E.O. expands the sanctions previously announced in response to recent actions of the Government of the Russian Federation in Crimea to include any person who is determined to:
- Be an official of the Government of the Russian Federation;
- Operate in the arms or related materiel in the Russian Federation;
- Be owned or controlled by, or to have acted or purported to act
for or on behalf of, directly of indirectly:
- a senior official of the Government of the Russian Federation; or
- a person whose property and interests in property are blocked pursuant to this order; or
- Have materially assisted, sponsored, or provided financial,
material, or technological support for, or goods or services to or
in support of:
- a senior official of the Government of the Russian Federation; or
- a person whose property and interests in property are blocked pursuant to this order.
Effective immediately, all property and interests in property
that are in the control of U.S. persons (including foreign
branches) will be blocked, and subject persons will be prohibited
from entry to the United States. The complete list of blocked
persons is available here.
As the situation in Ukraine continues to unfold and sanctions are
expanded, U.S. companies should be particularly cautious in
screening transactions in the region and maintaining records. In
addition, companies with affiliates in the European Union should be
mindful of changes to EU sanctions that could impact business in
the region.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
