US and EU impose further sanctions in relation to actions in Ukraine

This e-alert provides an update on the US and EU sanctions discussed in the Allen & Overy e-alerts dated 13 March 2014, titled ‘United States and European Union authorise sanctions relating to situation in Ukraine’; 18 March 2014, titled ‘US and EU expand sanctions relating to the Ukraine’; and 27 March 2014, titled ‘Ukraine: US and EU expand the list of persons subject to sanctions’ (the 13 March e-alert, the 18 March e-alert and the 27 March e-alert).

On 28 April 2014, in response to the ongoing situation in Ukraine, the US designated 24 additional individuals and entities for sanctions under Executive Order 13661 (EO 13661). EO 13661, signed by US president Barack Obama on 16 March 2014, authorises the imposition of visa restrictions on, and the freezing of the US property and financial assets of, persons the US government determines to be responsible for or complicit in undermining democratic processes and institutions in Ukraine, threatening its peace, security, stability, sovereignty and territorial integrity and contributing to the misappropriation of its assets.

On 14 April 2014, the Council of the European Union agreed to take further action against certain individuals in relation to the misappropriation of Ukrainian state funds and alleged human rights violations in Ukraine. The council adopted Implementing Decision 2014/216/CFSP and Implementing Regulation (EU) No 381/2014, which expand the list of individuals targeted with a travel ban and a freeze of their assets within the EU…

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