On March 17, 2014, President Obama signed a new Executive Order (“March 17 EO”), expanding on the Executive Order issued on March 6, 2014 (“March 6 EO”) relating to the unrest in Ukraine. The March 17 EO authorizes the United States to impose sanctions on senior officials of the Government of the Russian Federation, as well as on individuals or entities operating in the arms or related materiel sector in the Russian Federation. The March 17 EO also provides the authority for designation of any individual or entity that is owned or controlled by, or provides material or other specified support to any senior official of the Government of the Russian Federation or any person designated pursuant to this order. The March 17 EO was issued in direct response to the referendum held on Sunday, March 16 in Crimea regarding secession from Ukraine.
The March 17 EO authorizes blocking the property and interests in property located in the United States or in the possession or control of a US Person of any person (including individuals and entities) found to be...
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