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Effective 19 December 2014, President Obama issued an Executive Order that (i) imposes comprehensive sanctions on the Crimea region of Ukraine (“Crimea”), which has been occupied by Russia since March 2014, and (ii) provides the authority for blocking certain persons in connection with the situation in Crimea. OFAC’s announcement is available here. The Executive Order prohibits the following activities:

  • New investment in Crimea by U.S. Persons (i.e., (i) entities organized under U.S. laws and their non-U.S. branches, (ii) persons located in the United States (even temporarily), and (iii) U.S. citizens and permanent resident aliens, wherever located or employed);
  • Imports into the United States, directly or indirectly, of any goods, services or technology from Crimea;
  • Exports, reexports, sale, or supply, directly or indirectly, from the United States or by a U.S. Person, of any goods, services or technology to Crimea; and
  • Any approval, financing, facilitation, or guarantee by a U.S. Person of a transaction by a foreign person that would be prohibited if performed by a U.S. Person.

The Executive Order also includes expansive authority to block any person determined by the U.S. Government to (i) operate in Crimea, (ii) be a leader of an entity operating in Crimea, (iii) be owned or controlled by, or have acted on behalf of any person who is blocked under the Executive Order, or (iv) have “materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, any person” who is blocked under the Executive Order. Simultaneous to the Executive Order, OFAC issued General License No. 4 that authorizes certain exports/reexports to Crimea of agricultural commodities, medicines, medical supplies, and associated replacement parts. The applicable conditions resemble those required for the comparable general license under the Iran sanctions program. Finally, OFAC also designated a number of individuals and entities as Specially Designated Nationals (“SDNs”) in today’s action under pre-existing Ukraine-related Executive Order 13660. The list of new SDNs is available here. By Janet Kim and Maria H. van Wagenberg (Baker & McKenzie Washington D.C.)


Janet Kim is a partner in Baker McKenzie's Washington, DC office. Ms. Kim advises clients — including US and foreign companies —on outbound compliance issues arising from the US Foreign Corrupt Practices Act, as well as in criminal and regulatory proceedings, internal investigations and compliance reviews relating to these areas of law. She also advises on the application of these laws in cross-border transactions, including mergers and acquisitions, divestitures and joint venture arrangements. Additionally, Ms. Kim helps develop and implement workable, risk-based compliance programs for companies in a wide range of industries.

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