On Friday, September 12, 2014, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) expanded Ukraine-related sanctions by taking several actions to broaden the scope of US “sectoral” sanctions issued pursuant to Executive Order 13662 to cover the Russian defense sector and additional parties and activities in the Russian energy sector and by designating 5 Russian defense companies as Specially Designated Nationals (“SDNs”). On the same day, the US Commerce Department’s Bureau of Industry…
On Wednesday, August 13, 2014, the US Office of Foreign Assets Control (“OFAC”) issued “Revised Guidance on Entities Owned by Persons Whose Property and Interests in Property are Blocked” (the “revised guidance”). This revised guidance is effective today, August 14, 2014, pursuant to its publication in the Federal Register. This revised guidance replaces previous guidance that OFAC issued on this topic on February 14, 2008 (the “previous guidance”). U.S. Persons are prohibited from dealing, directly…