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Sanctions Targeting Crimea

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The European Foreign Affairs Council today unanimously approved the designation of 19 persons and 9 entities involved in action against Ukraine’s territorial integrity, though their designation has been delayed until 16 February 2015 and it is suggested will depend on “current diplomatic efforts”.  Their identity has not yet been revealed, though it is reported that the list includes 14 separatists, five Russians (rumoured to include Russian Deputy Defence Minister Anatoly Antonov) and one Russian entity.…

On January 30, 2015, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued three Ukraine-related general licenses authorizing certain transactions relating to Crimea that would otherwise be prohibited under Executive Order 13685.  As detailed in our recent post, Executive Order 13685 imposed comprehensive sanctions on the Crimea region of Ukraine and provided the authority for blocking certain persons in connection with the situation in Crimea.  Consistent with Executive Order 13685, the US Government…

The US Commerce Department’s Bureau of Industry and Security (“BIS”) is issuing a final rule amending the Export Administration Regulations, 15 C.F.R. Part 730 et seq. (“EAR”), to impose a license requirement on the export, reexport, or transfer by any person of virtually all “items subject to the EAR” to or within the Crimea region of Ukraine.  The final rule will come into effect tomorrow, January 29, 2015, upon publication in the Federal Register.  It…

On 18 December 2014, the European Union significantly extended its trade sanctions in relation to Crimea and Sevastopol. Regulation 1351/2014 (“the Regulation”) amends Regulation 692/2014 as amended by Regulation 825/2014. The main elements of the new regulation are as follows: · a very significant extension of restrictions on the areas already covered in the earlier Regulations; and an extension to new areas (e.g. real estate and tourism services); · broadening of the restrictions already in…