Issuance of a new Ukraine-related Executive Order

As you know, sanctions have profound ripple effects and with the U.S. response to the continuing crisis in Crimea, it is imperative you ensure that these newly-ordered sanctions don’t trickle down to doing business with your trading partners.

Executive Order 13660 signed by President Obama on March 6 in response to the current political crisis in Ukraine, imposed targeted sanctions against specifically named persons listed on the Treasury Department’s Specially Designated Nationals (‘SDN’) List. The Order froze the assets of these individuals, imposed immigration restrictions on them, and rendered it illegal for any US person or entity to transact with or donate to such individuals or entities.

The second Ukraine-related executive order signed by the President on Monday specifically condemns the Russian government for its actions in Crimea, opening the door to the addition of Russian individuals and entities to the SDN list.

What you need to do:  Ensure your trading partners are not on the SDN list! Run the name of all potential business partners against the SDN list.  Treasury adds and removes people from the list daily. So for now, the sure-fire way to avoid a sanctions violation remains straightforward: check the SDN list early and often. As the situation unfolds, we’ll make sure to let you know of any changes in US policy towards Ukraine and Russia that may affect your business.

For a concise description of the historical context and political tensions that have led to the crisis in Crimea and an analysis of reactions from the particular individuals that have been targeted by U.S. and EU sanctions thus far, take a look at this New York Times article by Steven Lee Myers and Peter Baker. As you’ll see, it appears very likely that these sanctions will be expanded in the coming days and weeks…stay tuned.