US and EU expand sanctions relating to Ukraine
On 17 March 2014, US president Barack Obama signed an executive order (EO) authorising additional sanctions (namely visa restrictions and the freezing of US property and financial assets) against persons the US has deemed to be contributing to the ongoing situation in Ukraine. Citing the actions and policies of the government of the Russian Federation with respect to Ukraine — including ‘the recent deployment of Russian Federation military forces in the Crimea region of Ukraine’ — the EO expands the scope of the national emergency declared in EO 13660, issued on 6 March 2014. Specific individuals have now been designated for sanctions under the EOs and added to the US Department of the Treasury’s Office of Foreign Assets Control’s (OFAC’s) Specially Designated Nationals List (SDN List).
Additionally, further to the financial sanctions imposed on certain individuals by the EU last week, on 17 March 2014 the European Council adopted further restrictive measures against persons it has deemed responsible for ‘actions that undermine or threaten the territorial integrity, sovereignty and independence of Ukraine’. Specifically, the European Council has adopted Council Decision 2014/145/CFSP and Council Regulation (EU) No 269/2014, which provide for the imposition of travel restrictions on, and the freezing of funds and economic resources of, certain individuals.
The introduction of US and EU sanctions regimes relating to the situation in Ukraine may pose challenges to both companies and financial institutions, particularly those with business dealings involving Ukraine, Russia and/or individuals or entities targeted by these measures. Such challenges may be heightened if the US and EU expand the number of persons designated for sanctions particularly if, as is the stated intention of the Russian government, Russian legislators respond with similar legislation…
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