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…

Effective at 3:30 pm ET today, President Obama issued an Executive Order  that (i) imposes comprehensive sanctions on the Crimea region of Ukraine (“Crimea”), which has been occupied by Russia since March 2014, and (ii) provides the authority for blocking certain persons in connection with the situation in Crimea .  OFAC’s announcement is available here.  The Executive Order prohibits the following activities: New investment in Crimea by U.S. Persons (i.e., (i) entities organized under US…