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United States Expands Sanctions in Response to Activities in Ukraine, Names First SDNs (Specially Designated Nationals)

Earlier today, President Obama signed an Executive Order (E.O.) expanding on E.O. 13660, which was issued on March 10, 2014.  In addition to naming specific persons subject to the restrictions of E.O. 13660, including former Ukrainian President Viktor Yanukovych, the new E.O. expands the sanctions previously announced in response to recent actions of the Government of the Russian Federation in Crimea to include any person who is determined to:

  • Be an official of the Government of the Russian Federation;

  • Operate in the arms or related materiel in the Russian Federation;

  • Be owned or controlled by, or to have acted or purported to act for or on behalf of, directly of indirectly:

    • a senior official of the Government of the Russian Federation; or

    • a person whose property and interests in property are blocked pursuant to this order; or

  • Have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of:

    • a senior official of the Government of the Russian Federation; or

    • a person whose property and interests in property are blocked pursuant to this order.

Effective immediately, all property and interests in property that are in the control of U.S. persons (including foreign branches) will be blocked, and subject persons will be prohibited from entry to the United States.  The complete list of blocked persons is available here.

As the situation in Ukraine continues to unfold and sanctions are expanded, U.S. companies should be particularly cautious in screening transactions in the region and maintaining records.  In addition, companies with affiliates in the European Union should be mindful of changes to EU sanctions that could impact business in the region.

© 2020 Faegre Drinker Biddle & Reath LLP. All Rights Reserved.National Law Review, Volume IV, Number 77

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About this Author

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

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...

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