Bridge ConstuctionOn September 1, 2016, the Office of Foreign Assets Control (OFAC) placed sanctions on 37 new individuals and entities to prevent attempts to circumvent U.S. sanctions against Russia, help the private sector with compliance and to foster a diplomatic resolution to the conflict in Ukraine. The new list (found here) includes 17 separatists in eastern Ukraine or Russian-occupied Crimea, including 11 officials operating in Crimea.  18 companies operating in Crimea, including a number of construction, defense and maritime firms, and a Ukrainian charity were added to the Specially Designated Nationals (SDN) list.  The list includes construction companies, PJSC Mostotrest and SGM –Most OOO, which were awarded contracts to complete the Kerch Strait Bridge to connect Russia to Crimea.
Continue Reading U.S. Expands Russia/Ukraine Sanctions to Target Evasion

Treasury Building_155316661The U.S. Department of Treasury, Office of Foreign Asset Control (OFAC), this week imposed sanctions on fourteen additional Ukrainian and Russian individuals and two organizations, including the Russian National Commercial Bank (RNCB), by adding them to the Specially Designated Nationals (SDN) list. These designations were issued pursuant to Executive Order (E.O.) 13660 for undermining Ukraine’s sovereignty and misappropriation of Ukrainian states assets, and E.O. 13685 for operating in Crimea Region.

Treasury stated that the RNCB was added to the sanctions list because it had no presence in the Crimea region prior to the occupation by Russia, and because Russian authorities have illegally used the bank in efforts to incorporate Crimea into the Russian Federation.


Continue Reading U.S. Expands Ukrainian and Crimean Sanctions

On December 18, 2014, President Obama signed the Ukraine Freedom Support Act of 2014 (UFSA) into law,broadening the Administration’s authority to impose sanctions in response to continued Russian activity in Ukraine. Although the legislation authorizes the President to increase sanctions, he has stated that “this does not signal a change in the Administration’s sanctions policy” and the Administration does not intend to impose further sanctions at this time.

Continue Reading President Obama Signs Ukraine Freedom Support Act of 2014

Yesterday, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced increased economic sanctions against Russia, including measures against Russia’s largest bank – Sberbank Russia – as well as several state-owned defense technology companies and five energy companies (Gazprom, Gazprom Neft, Lukoil, Surgutneftegas and Rosneft).  The United States has also tightened previous restrictions by lowering from 90 days to 30 days the allowable length of debt U.S. citizens and entities may buy from sanctioned Russian banks – Bank of Moscow, Gazprombank OAO, Vnesheconombank (VEB), Russian Agricultural Bank (Rosselkhozbank),  VTB Bank OAO and Sberbank Russia.
Continue Reading US and EU Tighten Sanctions against Russian Banks, Defense and Energy Sectors

As described in our Alert published on August 1, 2014, the United States and other nations have ramped up sanctions against Russia related to the ongoing situation in Ukraine.

On July 31, 2014, the European Union imposed increased sanctions designed to discourage Russia from, in the words of the EU Regulation, “destabilising the situation in Ukraine.”


Continue Reading EU Increases Sanctions Against Russia

In response to Russia’s continuing actions in Ukraine, the United States and other nations have implemented increased economic sanctions that significantly broaden the scope of the sanctions previously in place. In addition to the U.S. actions, Canada, the European Union and Japan have imposed similar sanctions against Russia, including asset freezes and individual designations.

Continue Reading U.S. and Others Step Up Sanctions Against Russia

Recently, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) promulgated regulations which formally implement the Ukraine-related sanctions set forth in Executive Orders 13660 (“Blocking Property of Certain Persons Contributing to the Situation in Ukraine”), 13661 (“Blocking Property of Additional Persons Contributing to the Situation in Ukraine”), and 13662 (“Blocking Property of Additional Persons Contributing to the Situation in Ukraine”). OFAC has made numerous designations of entities and individuals under the executive orders, which can be reviewed here.

The new regulations, entitled the Ukraine-Related Sanctions Regulations (URSR)  31 CFR Part 589, have been published in abbreviated form in an effort to provide immediate guidance to the public. OFAC has indicated that it intends to supplement the regulations in the near future with a more comprehensive set of regulations which may include additional guidance on interpretations and definitions, as well as additional general licenses and statements of licensing policy.


Continue Reading Ukraine-Related Sanctions Update: OFAC Issues Sanctions Regulations; President Withdraws GSP Status for Russia