Ukraine Related Russian Sanctions
A number of governments have applied sanctions against businesses and individuals in Russia in response to the Russian invasion of Ukraine. These sanctions have been approved by the United States and the European Union with Russia responding with a ban on food imports from both. The first round of Russian Sanctions by the United States were ordered by President Obama on March 6, 2014. Japan also announced sanctions at this time.
Australia imposed sanctions on Russian after its annexation of Crimea. A second round of Russian Sanctions was imposed on April of 2014 by President Obama. The European Union followed by issuing its own Russian Sanctions along with Albania, Iceland and Montenegro.
As the war escalated in Donbass (Ukraine), a third round of Russian Sanctions was imposed on July 16, 2014 by the United States. Shortly thereafter, the EU expanded its sanctions on Russia.
In August of 2014, the U.S. Treasury Department issued its Sectoral Sanctions Identifications List which has grown steadily since then to include much of the leadership of the Russian Federation and Russian Industry. These Russian Sanctions are against individuals and their ownership of certain businesses. The intent is to cripple specific “sectors” in the Russian Economy, and in the United States these are known as “Sectoral Sanctions”. This is managed by the U.S. Treasury’s Office of Foreign Assets Control (OFAC) and the regulations may be found in 31 CFR Part 589 – Ukraine-Related Sanctions Regulations.
With the new extensive sanctions issued by the United States, NATO alliance, and many civilized countries around the world, the application of transactions with Russians and the Russian Government must be strictly scrutinized. The sanction lists and permissible transactions are changing day to day, and failure to adhere to the sanctions will result in severe criminal and pecuniary liabilities. As such, it is highly recommended for you to discuss any international transactions you are contemplating to undertake with a an export compliance attorney.
Arcadier, Biggie & Wood, PLLC is partnered with CVG Strategy, a consultancy, to provide a solution to businesses wanting to ensure compliance with these Russian Sanctions or Sectoral Sanctions imposed by the United States Treasury Department. This white paper explains the Russian Sanctions and the approach to solving the problem.