The US blocks the property of 11 persons, the EU freezes the assets of another 21 individuals, and a new US Executive Order authorizes future blocking actions.

In response to the continuing political crisis in Ukraine and Sunday’s widely reported referendum on the status of Crimea, the United States and the European Union have expanded their targeted sanctions against certain Ukrainian and Russian persons. These measures build on the initial rounds of sanctions imposed on March 5 and 6, 2014, described in our previous Client Alert dated March 7, 2014. While these new actions expand the framework for possible further sanctions in the days ahead, the measures imposed to date continue to be targeted and limited in their reach.

On March 17, 2014, the US President issued an Executive Order (EO) expanding upon Executive Order 13660 (EO 13660) of March 6. The new EO blocks the property of persons found to have “undermine[d] democratic processes and institutions in Ukraine” or contributed to the “misappropriation of [Ukraine’s] assets.” The current list of blocked persons includes seven individuals identified in the annex to the EO1 and four individuals simultaneously designated by the US Department of the Treasury under EO 13660. In addition, unlike EO 13660, the new EO explicitly includes “official[s] of the Government of the Russian Federation” as persons who may be subject to blocking.

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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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