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Sanctions Targeting Crimea

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OFAC Extends Expiration Date of General Licenses Related to RUSAL, EN+ Group, and GAZ Group and Imposes Secondary Sanctions on Parties Supporting Russia’s Occupation of Crimea

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Extension of General Licenses

On November 9, 2018, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) temporarily extended the expiration dates of four general licenses related to EN+ Group PLC (“EN+”), United Company RUSAL PLC (“RUSAL”), and GAZ Group (“GAZ”) from December 12, 2018 to January 7, 2019. Please see our blog posts on the original designation of these companies and previous extensions of these general licenses here and here. The Treasury Department press release indicates that EN+, RUSAL, and GAZ are proposing substantial corporate governance changes that could potentially result in significant changes in control and ultimately lead to these entities’ removal from the Specially Designated Nationals and Blocked Persons List (“SDN List”).

EU extends Crimea/Sevastopol Sanctions for one year

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On 18 June 2018, the Council of the EU extended its sanctions programme in response to Russia’s annexation of Crimea and Sevastopol for one year until 23 June 2019 (see Council Decision (CFSP) 2018/880). These sanctions continue to apply to EU persons and EU based companies. By way of reminder, the measures include prohibitions on: imports of products originating in Crimea or Sevastopol into the EU; investment in Crimea or Sevastopol (No Europeans or EU-based…

US Government Designates Additional Parties Under US Sanctions Targeting Russia and Crimea

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On June 20, 2017, the US Office of Foreign Assets Control (“OFAC”) announced that it had added 38 individuals and entities to the Specially Designated Nationals and Blocked Persons List (“SDN List”) and 20 entities to the Sectoral Sanctions Identification List (“SSI List”) under US sanctions targeting Russia and Crimea.  On June 21, 2017, the US Bureau of Industry and Security (“BIS”) also announced that it would add some of these SDN entities to the Entity List.

Canada names additional Crimean individuals as designated persons

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On November 28, 2016, the Government of Canada further expanded its sanctions against the Crimea region of Ukraine, which are contained in the Special Economic Measures (Ukraine) Regulations (the “Regulations”) made pursuant to the Special Economic Measures Act. The amendments add 15 additional individuals to the list of designated persons in Schedule 1 of the Regulations.  The newly designated persons include six members of Russia’s State Duma from Crimea.  According to a Global Affairs Canada…

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