Ukrainian Sanctions (with Turza Comment)

In response to an escalating crisis, on March 6, 2014, President Obama issued Executive Order 13660 (linked below), blocking the property of certain persons contributing to the unstable situation in Ukraine. The Order allows the U.S. to impose economic sanctions against persons (individuals and entities) who are determined to be responsible for or complicit in activities that undermine the democratic process in Ukraine or threaten the peace, security, stability, sovereignty or territorial integrity of the country, including those who have provided material or financial assistance to such persons. The Order also targets those who are determined to have misappropriated the assets of Ukraine or any "economically significant entity" in the country. While the authority to name persons under the Executive Order clearly exists, the U.S. government has yet to name anyone.

Turza Comment: Speculation is rampant that the first set of individuals might be the same as those who were named by the European Union last week (see attached HM Treasury's Financial Sanctions Notice implementing EU Council Regulation No. 208/2104). In the meantime, the U.S. House of Representatives, whose Committee on Foreign Affairs held hearings last Thursday on "U.S. Foreign Policy toward Ukraine," continues to contemplate a Resolution on the issue, although no date for a vote has been scheduled. Please contact Dale Turza at 202-862-2261 or [email protected] should you have any questions.

See: Executive Order 13360.See also: EU Council Regulation No.208.2104.