Ukrainian and Iranian Sanctions Update (with Turza Comment)
Ukraine-Related Sanctions:
The European Union announced on April 29 that it was imposing sanctions on additional Russian and Ukrainian individuals who have "taken actions undermining Ukraine's territorial integrity." Specifically, the EU added 15 individuals to its list of persons subject to travel bans and asset freezes, including high-level Russian political and military leaders, as well as pro-Russian Ukrainian separatists who have taken part in the seizure of government buildings throughout eastern Ukraine in the last few weeks. Notable additions to the EU's list of sanctioned individuals are Russian Deputy Prime Minister Dmitry Kozak, Chief of the General Staff of the Armed Forces of the Russian Federation Gen. Valery Gerasimov, and Lt. Gen. Igor Sergun, Director of the GRU, which is Russia's military intelligence directorate. Since mid-March, the EU has imposed sanctions on 70 persons for actions related to the ongoing crisis in eastern Ukraine.
In a more unexpected move, Japan also announced on April 29 that it was imposing sanctions in the form of visa bans on twenty-three Russian and Ukrainian individuals. While Japan had responded last month to Russia's actions in Ukraine by suspending talks over the relaxation of visa requirements and treaty negotiations related to investment, space exploration cooperation, and the prevention of dangerous military activities, the current action is Japan's first concerning the Ukraine crisis that targets specific individuals. Russia called Japan's move a "clumsy step . . . clearly taken under outside pressure. . . ." Japan has not yet released the names of the twenty-three sanctioned persons.
An updated list of Russian and Ukrainian individuals and entities sanctioned by all jurisdictions is available here.
Iran:
Also on April 29, the Office of Foreign Assets Control ("OFAC") announced U.S. sanctions on individuals and entities for aiding Iran's ballistic missile program and for helping Iran to avoid oil sector sanctions pursuant to Executive Orders 13382 and 13645, respectively. (See OFAC Changes to List of Specially Designated Nationals and Blocked Persons List.) The entities named under Executive Order 13382, in connection with Iran's missile program, are alleged to be the Chinese "front companies" of Karl Lee, whom OFAC describes as "a known proliferator for Iran's ballistic missile program," and who was himself designated in April 2009. The persons named under Executive Order 13645 are Saeed al-Aqili, his company, Ali Aqili Group LLC, and Anwar Kamal Nizami. Both Aqili and Nizami are accused of assisting Iran in disguising the origin of its oil and otherwise evading sanctions.
Turza Comment: The EU's new sanctions continue to reflect Europe's general unwillingness to target individuals or entities whose inclusion could threaten broader European-Russian economic ties. The EU has not yet named an entity to its sanctions list, nor has it targeted any oligarchs or Putin "cronies," such as Gennady Timchenko, the Rotenberg brothers, Yuri Kovalchuk or Igor Sechin. As the crisis deepens in Ukraine, the United States will be faced with a difficult choice: proceed with sector-based sanctions that could have significant ramifications for its European allies or continue with small-bore targeted sanctions that may be insufficient to halt Russian intervention.Meanwhile, the imposition of sanctions in connection with Iran's nuclear program reminds companies that OFAC runs dozens of sanctions programs affecting individuals, entities and countries across the world. The latest Iran designations were made even as the parties continued to negotiate a comprehensive solution to the question of Iran's nuclear program within the P5+1 framework. Whether those talks will be affected by OFAC's designations - or, more generally, by rising tensions between Russia and the West - remains to be seen.
See: OFAC Changes to List of Specially Designated Nationals and Blocked Persons List; OFAC Press Release; Updated List of Russian and Ukrainian Individuals and Entities Sanctioned.See also: Cabinet Sanctions Page (accessible to Cabinet subscribers only). For more information, please contact Dale Turza and James Treanor.