U.S. and EU impose further sanctions in relation to actions in Ukraine
12 May 2014
This E-Alert provides an update on the U.S. and EU sanctions discussed in the Allen & Overy E-Alerts dated March 13, 2014, titled “United States and European Union authorize sanctions relating to situation in Ukraine”; March 18, 2014, titled “U.S. and EU expand sanctions relating to the Ukraine”; and March 27, 2014, titled “Ukraine: U.S. and EU expand the list of persons subject to sanctions” (the March 13 E-Alert, March 18 E-Alert and March 27 E-Alert).
Please see section entitled "Further Information" for links to these E-Alerts.
On 28 April 2014, in response to the ongoing situation in Ukraine, the United States designated twenty-four (24) additional individuals and entities for sanctions under Executive Order 13661 (EO 13661).1 EO 13661, signed by U.S. President Barack Obama on 16 March 2014, authorizes the imposition of visa restrictions on, and the freezing of the U.S. property and financial assets of, persons the U.S. Government determines to be responsible for or complicit in undermining democratic processes and institutions in Ukraine; threatening its peace, security, stability, sovereignty, and territorial integrity; and contributing to the misappropriation of its assets.
On 14 April 2014, the Council of the European Union agreed to take further action against certain individuals in relation to the misappropriation of Ukrainian State funds and alleged human rights violations in Ukraine. The Council adopted Implementing Decision 2014/216/CFSP2 (the April 14 Implementing Decision) and Implementing Regulation (EU) No 381/20143 (the April 14 Implementing Regulation), which expand the list of individuals targeted with a travel ban and a freeze of their assets within the EU.
Furthermore, on 28 April 2014, the Council of the European Union decided to expand the list of persons sanctioned in relation to "actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine". In this regard, the Council adopted Implementing Decision 2014/238/CFSP4 (the April 28 Implementing Decision) and Implementing Regulation (EU) No 433/20145 (the April 28 Implementing Regulation), which further expand the list of individuals targeted with a travel ban and a freeze of their assets within the EU.
This brings the total number of persons subject to EU sanctions in connection with the crisis in Ukraine to 70 (and 57 persons and entities are subject to U.S. sanctions).
The expansion of U.S. and EU sanctions lists relating to the situation in Ukraine may pose challenges to companies and financial institutions with business dealings involving individuals or entities targeted by these measures. Such challenges may be heightened if the U.S. and EU continue to expand the number of persons designated for sanctions.
U.S. Sanctions: Additional designations
On 28 April 2014, in response to the evolving situation in Ukraine, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated additional individuals and entities for sanctions under EO 13661 and added these individuals and entities to OFAC’s list of Specially Designated Nationals (SDN List). The latest designations include various companies, officials and private individuals with ties to the Russian government and Russian President Vladimir Putin, as well as Russia’s energy and oil and gas sectors.
Additional persons designated for U.S. sanctions under EO 13661
The following persons have been designated for sanctions under EO 13661 and added to OFAC’s SDN List:
- BELAVENCEV, Oleg Evgenyevich; Russian Presidential Envoy to the Crimean District; Member of the Russian Security Council;
- CHEMEZOV, Sergei;
- KOZAK, Dmitry; Deputy Prime Minister of the Russian Federation;
- MUROV, Evgeniy Alekseyevich; Director of the Federal Protective Service of the Russian Federation; Army General;
- PUSHKOV, Aleksei Konstantinovich; Chairman of State Duma Committee on International Affairs;
- SECHIN, Igor; and
- VOLODIN, Vyacheslav; First Deputy Chief of Staff of the Presidential Executive Office.
Additional entities designated for U.S. sanctions under EO 13661
The following entities have been designated for sanctions under EO 13661 and added to OFAC’s SDN List:
Pursuant to EO 13661, all property and interests in property that are or come within the United States or that are or come within the possession or control of any United States person of these persons must be blocked and may not be transferred, paid, exported, withdrawn, or otherwise dealt in. Additionally, the immigrant and non-immigrant entry into the United States of these persons is suspended. For further discussion of the sanctions authorized by EO 13661 and other related developments, please see the March 13, March 18 and March 27 E-Alerts, as well as Allen & Overy’s April 15 update titled "United States Updates List of Specially Designated Nationals Relating to Situation in Ukraine", available here: