Additional EU and US sanctions

There has been further escalation of EU and US sanctions resulting from the events in Ukraine, including new designations and the issuance of a new executive order (EO) on 20 March 2014 that provides additional legal basis for future designations and a new EU regulation that adds 12 persons to the list of natural and legal persons, entities and bodies subject to the EU sanctions.

The Russian government has responded to the initial sanctions so far by imposing a travel ban on certain US government officials, but additional retaliatory measures in response to the new EO are being considered. Companies with operations in Russia should remain vigilant and assess whether new designations have an impact on their current activities and how the expanded authority for future designations may affect their operations, based on sectors/industries that could be targeted by the US government pursuant to the authority set forth in the new EO.

On 20 March 2014, the US government designated additional Russian individuals as well as one Russian bank under EO 13661 from 17 March 2014. US persons are prohibited from engaging in transactions with designated persons and entities, including any entities that are owned (at 50 per cent or higher interest) or otherwise controlled by designated persons…

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