Early March 18, 2014, 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.
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