US TREASURY IMPOSES SANCTIONS IN VIEW OF THE SITUATION IN UKRAINE

On 11 March 2015, the US Treasury Department announced that it has designated fourteen individuals and two entities as Specially Designated Nationals (‘SDN’) in view of the situation in Ukraine.  The designations are made pursuant to Executive Order 13660 and target individuals and entities alleged to be separatists responsible for or complicit in actions or policies that threaten the peace, security, stability, sovereignty, or territorial integrity of Ukraine.

Under the sanctions, listed individuals and entities will be barred from entering the United States, will have all of their assets within United States jurisdiction frozen, and US persons will generally be prohibited from engaging in transactions with them.

The individuals listed include eight Ukrainian separatists and the leaders of one pro-separatist Russian entity.  The entities listed are:

  1. Eurasian Youth Union
  2. Russian National Commercial Bank

Speaking on 11 March 2015, US Acting Under Secretary for Terrorism and Financial Intelligence Adam J Szubin stated that “From the start of this crisis, we have demonstrated that we will impose costs on those who violate the sovereignty and territorial integrity of Ukraine”, adding that “If Russia continues to support destabilising activity in Ukraine and violate the Minsk agreements and implementation plan, the already substantial costs it faces will continue to rise”.

The US Treasury department notes that it continues “to work to remain in lockstep with our international partners in an effort to incentivise a diplomatic resolution to the crisis in Ukraine”, and that “the sanctions follow similar action taken by the European Union and Canada” on 16 February 2015 (see previous blogs here and here).

A list of sanctions in force against Ukraine can be found in the “sanctions in force” section of this blog.

This entry was posted in Ukraine, USA by Michael O'Kane. Bookmark the permalink.

About Michael O'Kane

Michael O’Kane is a partner and Head of the Business Crime team at leading UK firm Peters & Peters. Described as ‘first-rate’ (Legal 500 2012), he “draws glowing praise from commentators” (Chambers 2013) for handling the international aspects of business crime, including sanctions, extradition and mutual legal assistance. Called to the Bar in 1992 and prior to joining Peters & Peters he was a senior specialist prosecutor at the Crown Prosecution Service Headquarters(CPS). At CPS HQ he was a key member of a small specialist unit responsible for the prosecution of serious and high profile fraud, terrorist and special interest criminal matters including the Stansted Airport Afghan hijacking and the prosecution of Paul Burrell (Princess Diana’s butler). Michael joined Peters & Peters in 2002. He became a partner in May 2004, and Head of the Business Crime team in May 2009. Since joining Peters & Peters, Michael has dealt with a wide range of business crime matters. He has particular expertise in international sanctions, criminal cartels, extradition, corruption, mutual legal assistance, and FSA investigations. Described as“ an influential practitioner in fraud and regulatory work, so much so that he is top of the referral lists of many City firms for independent advice for directors” (The Lawyer’s Hot 100 2009), he was recognised as one of the UK’s most innovative lawyers in the 2011 FT Innovative Lawyer Awards and included in the list of the UK's leading lawyers in 'The International Who's Who of Asset Recovery 2012. In 2012 he was the winner of the Global Competition Review Article of the Year. Michael regularly appears on television and radio to discuss his specialist areas and he is the author of the leading textbook on the UK Criminal Cartel Offence “The Law of Criminal Cartels-Practice and Procedure” (Oxford University Press 2009). Recent/Current Sanctions Work • Representing 109 individuals and 12 companies subject to designation by the European Council under targeted measures imposed against Zimbabwe. This is the largest and most complex collective challenge to a sanctions listing ever brought before the European Court. • Acting for a former Egyptian Minister and his UK resident wife, challenging their designation by the European Council of Ministers under targeted measures brought against former members of the Egyptian Government. • Advising a company accused in a UN investigation report to have breached UN sanctions imposed in relation to Somalia. • Advising a UK company in relation to ongoing commercial relationships with an Iranian company listed under both EU and UN sanctions. • Advising an individual in relation to a UK investigation for alleging breaching nuclear export controls.

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