New US Russia designations

US Treasury BuildingOFAC has designated 21 people and 9 entities, and added 12 entities to its Russia / Ukraine Sectoral Sanctions Identification List.

These measures were taken to “maintain sanctions pressure on Russia until it fully implements its commitments under the Minsk agreements” and to underscore the “US government’s opposition to Russia’s occupation of Crimea”.

11 people were designated pursuant to EO 13660 for being “Ukrainian separatists… responsible for or complicit in, or having engaged in, directly or indirectly, actions or policies that threaten the peace, security, stability, sovereignty, or territorial integrity of Ukraine; or for asserting governmental authority over a part or region of Ukraine without the authorization of the Government of Ukraine”. Pursuant to the same EO, OFAC also designated 3 people and 4 entities “who have supported the illicit coal trade from [Ukraine]”.

4 people and 2 entities were designated pursuant to EO 13661, which authorises sanctions against (inter alia) officials of the Russian government and any individual or entity that has acted for or on behalf of, or supported, an individual or entity previously designated under this EO.

1 construction company and 2 associated people were designated pursuant to EO 13685, which authorises sanctions against (inter alia) any person determined to operate in the Crimea region of Ukraine. Under the same EO, OFAC also designated 1 person and 2 entities “related to Russia’s transfer of four turbines made by a Russian-German joint venture to Crimea”.

OFAC also identified 12 subsidiaries that are 50% or more owned by Surgutneftegaz, an entity which was added to the Sectoral Sanctions Identification List (SSI List) in September 2014 under Directive 4.  The subsidiaries are subject to the same restrictions as their parent.  See OFAC’s revised guidance on Entities Owned by Persons Whose Property and Interests in Property Are Blocked (50% Rule). Links here for OFAC Notice and US Treasury press release.

This entry was posted in Russia, 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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