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December 22, 2014

Broad Sanctions on Transactions with the Crimea Region of Ukraine

On December 19, 2014, President Obama issued Executive Order 13685, which imposes very broad sanctions on transactions with persons and entities in the Crimea region of Ukraine. These restrictions are much broader than the sanctions imposed on Russia which have targeted certain key sectors of the Russian economy and specified (listed) individuals and entities. The latest sanctions on Crimea bear more similarities to the Iranian sanctions in that they broadly prohibit the exportation and importation of goods, services, and technology to/from the U.S. and the Crimea region of Ukraine. The Executive Order also bans new investments in Crimea by U.S. persons and provides the authority for blocking U.S. property interests of certain individuals and entities connected with the Crimea region.

In parallel with the President's issuance of the Executive Order, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) issued General License No. 4, which authorizes certain exports/reexports to Crimea of agricultural commodities, medicine, medical supplies, and associated replacement parts. OFAC added 24 individuals and entities to the list of Specially Designated Nationals (SDN). These additions to the SDN list are available here.

On December 30, 2014, OFAC published General License No. 5 to authorize certain activities necessary to wind-down operations involving the Crimea region of Ukraine. General License No. 5 authorizes U.S. persons to engage in transactions that are ordinarily incident and necessary to:

General License No. 5 authorizes such activities through 12:01 a.m. eastern daylight time, February 1, 2015.  The general license does not authorize any new exports or imports to/from Crimea or transactions dealing with any individuals on OFAC’s SDN List. U.S. Persons who wish to participate in transactions authorized by the general license must file a detailed report with OFAC within 10 business days after the conclusion of the wind-down activities.