On Thursday, 8 May 2014, the Office of Foreign Assets Control (“OFAC”) in the US Treasury Department issued the Ukraine-related Sanctions Regulations, 31 C.F.R. Part 589 (“URSR”), to implement Executive Orders 13660, 13661, and 13662 (“the Orders”). The abbreviated nature of the URSR reflects OFAC’s stated purpose of providing immediate guidance to parties subject to the Orders. OFAC has noted that it intends to provide more comprehensive regulations with additional guidance at a later date.
The URSR do not affect the scope or application of the Orders in any way. In fact, the Orders are included as appendices to the URSR, and the section of these regulations entitled “Prohibited Transactions” (i.e., § 589.201) merely incorporates the Orders by reference. The URSR do provide some basic sanctions information, including:
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interpretations of the application of the URSR, such as a restatement of the policy (also found on OFAC’s Ukraine-related sanctions webpage) that entities in which a Specially Designated National holds a 50% or greater interest are also blocked for purposes of the URSR; and
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a small number of general licenses that are commonly found in OFAC sanctions regulations, including general licenses for legal services and for certain deductions from blocked accounts.
Despite the limited impact of the URSR, the issuance of these regulations is an important step in formalizing the US Government’s Ukraine-related sanctions.
