Ratcheting up the Pressure: Reinforced Ukraine-related Sanctions on Russia

On September 12, 2014, the United States (“U.S.”) and European Union (“EU”) both announced expanded sanctions related to Russia and Ukraine. These measures seek to increase pressure on the Russian Government to stop threatening the territorial integrity of Ukraine. In general, the specific sanctions (i) target specific entities and individuals, (ii) limit access to financial markets, and (iii) prohibit certain oil related exports and activities.

U.S. SANCTIONS -

As a result of Russia’s annexation of Crimea and destabilization of Ukraine, in March 2014, President Obama issued a series of Executive Orders (“EOs”) authorizing U.S. Government sanctions against individuals and entities (“persons”) that have contributed to the conflict in Ukraine. Pursuant to the EOs, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) has implemented the Ukraine-related sanctions regime that (i) designates Russian and Ukrainian persons as Specially Designated Nationals and Blocked Persons (“SDNs”) and (ii) imposes targeted sanctions against entities in the Russian financial services, energy and defense sectors (the “Sectoral Sanctions”). In addition, on August 6, 2014, the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) imposed controls on the export of certain items to Russia for use in the oil and gas sectors.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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