The US sanctions against Russia — in an evolving context, key points for business

By Ignacio E Sanchez, Thomas M deButts and Melanie Garcia

Starting in March of this year, the US imposed economic sanctions in response to Russian-led actions in Ukraine. Since March, responding to the deteriorating situation, US sanctions have continued to escalate. For companies with business relationships in or related to Russia, this alert provides a recap of the current US sanctions.

The president is empowered to impose sanctions via general statutes, primarily the International Emergency Economic Powers Act (IEEPA). Under IEEPA, the president declares a threat to the national security and foreign policy of the US and then orders sanctions whereby ‘US persons’ are prohibited from doing business with the specific named targets of the sanctions. Between 6 March 2014 and 20 March 2014, president Obama issued three executive orders imposing sanctions related to the Ukraine situation.

Pursuant to his powers under IEEPA, the president can identify persons or parties that are the target of sanctions and also delegates authority to the Treasury Department’s Office of Foreign Assets Control (OFAC) to administer the sanctions, promulgate regulations and add names to the list of targeted persons or entities. As a result, on 2 May 2014, OFAC published the Ukraine-Related Sanctions Regulations, 31 CFR Part 589…

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