EU’s Ukraine-related sanctions — are you compliant?

In response to the developments in Ukraine unfolded by the Euromaidan protest movement in early February 2014, the EU Council on 5 March 2014 decided to impose restrictive measures against individuals who have been identified as being responsible for the misappropriation of Ukrainian state funds and/or human rights violations (Council Regulation [EU] No. 208/2014). On 17 March 2014, additional sanctions were announced by both the EU (Council Regulation [EU] No. 269/2014) and the US (US executive orders of 6 March 2014 and 17 March 2014) against certain Russian individuals associated with the declaration of the independence of Crimea. The EU further increased the scope of sanctioned individuals on 20 March 2014.

While the further course of political and diplomatic developments in Ukraine cannot be foreseen, the EU sanctions were set into force immediately, thus challenging EU businesses to revisit their relations with designated persons and the entities deemed to be associated with them.

The regulations impose the freezing of funds owned or held by any of the designated persons. Further, non-designated entities are subject to such a freeze in the event that they are held or ‘controlled’ by a designated person…

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