On March 6, 2014, President Obama issued an executive order “blocking property of certain persons contributing to the situation in Ukraine” (“the Order”), designed to address the extraordinary threats to democratic processes and institutions in Ukraine; the peace, security, stability, sovereignty and territorial integrity of Ukraine; and the national security and foreign policy interests of the United States.
As reflected in its title, the Order targets certain persons and entities, including but not limited to any individual or entity responsible for or complicit in, or which has engaged in, any actions or policies that: (1) undermine democratic processes or institutions in Ukraine; (2) threaten the peace, security, stability,sovereignty or territorial integrity of Ukraine; (3) involve the misappropriation of state assets of Ukraine or of an economically significant entity in the country; and/or (4) effect an assertion of government authority over any part or region of Ukraine without the authorization of the country’s government. The Order also authorizes sanctions against any entity that is owned or controlled by, or has acted or purported to act for or on behalf of, directly or indirectly, any of the classes of individuals or entities listed above.
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