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OFAC Takes Further Action Related to Crimea - Office of Foreign Assets Control

 On December 30, 2014, the Office of Foreign Assets Control (OFAC) in the Department of the Treasury issued General License No. 5 to authorize certain prohibited activities in order to wind down operations involving the Crimea Region of Ukraine to address activities prohibited by Executive Order 13685, issued on December 19, 2014.

EO 13685 created a comprehensive embargo against Crimea, prohibiting all exports of goods and services to, and imports from, Crimea, and added individuals to the Specially Designated Nationals (SDN) list. General License No. 4, also issued on December 19, authorized the exportation or reexportation of agricultural commodities, medicine, and medical supplies and their replacement parts.

The Ukraine Freedom Support Act of 2014 was also signed into law on December 18, 2014. The act sets the stage of mandatory sanctions in the next few months and authorizes other sanctions contingent on specified facts and circumstances.

It appears that the United States and the EU coordinated on the issuance of new Ukraine-related sanctions, as the EU expanded its sanctions on Crimea on December 18th as well. The EU’s new sanctions prohibit, among other things, investments in Crimea and Sevastopol, the buying of real estate in Crimea, and the exportation of certain types of goods.

© 2020 Faegre Drinker Biddle & Reath LLP. All Rights Reserved.National Law Review, Volume V, Number 8


About this Author

Mollie Sitkowski, Drinker Biddle Law Firm, Chicago, Trade Law Attorney

Mollie D. Sitkowski assists clients in ensuring their internal processes meet Customs' "reasonable care" standard. She assists clients with various aspects of trade law, including valuation, classification, free trade agreements, country of origin determinations, and auditing their import documentation to identify potential issues and risk areas. Mollie also supports clients with export compliance, including advising on export screening and classification, and filing license classification requests and voluntary disclosures with the Bureau of Industry...