On Friday, 20 June 2014, the Office of Foreign Assets Control (“OFAC”) in the US Treasury Department announced its fifth group of “Specially Designated Nationals” (“SDNs”) related to the crisis in Ukraine and added seven individuals in Ukraine to the US SDN List pursuant to Executive Order 13660.
“U.S. Persons” are now prohibited from dealing (directly or indirectly) with these SDNs and any entities owned 50% or more by any of these SDNs. “U.S. Persons” include (i) entities organized under U.S. laws and their non-U.S. branches, (ii) individuals or entities in the United States, or (iii) U.S. citizens or permanent resident aliens (“Green Card” holders) wherever located or employed. Non-U.S. Persons, including separately incorporated foreign subsidiaries of U.S. companies, may be subject to U.S. jurisdiction if they cause any SDN-related transactions to occur in whole or in part in the United States or anywhere by U.S. Persons.
According to the US Treasury Department press statement, the designated individuals are separatists in Ukraine who are responsible for or complicit in actions or policies that threaten the peace, security, stability, sovereignty, or territorial integrity of Ukraine, and/or asserting governmental authority over a part or region of Ukraine without the authorization of the Government of Ukraine. The press statement indicates that the designated individuals have contributed to attempts to illegally undermine the legitimate Ukrainian government in Kyiv by falsely proclaiming leadership positions and fomenting violent unrest.
The seven SDN individuals announced on 20 June are:
-
Vyacheslav Ponomaryov
-
Denis Pushilin
-
Andrey Yevgenyevich Purgin
-
Igor Vsevolodovich Girkin
-
Valery Bolotov
-
Sergei Ivanovich Menyailo
-
Valery Vladimirovich Kaurov
