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Since the first round of sanctions targeting Russia, Shearman & Sterling has advised banks, financial institutions, commercial companies and clearing houses in relation to complex cross-border sanctions issues. The firm has also delivered presentations on Russia sanctions and undertaken numerous lobbying efforts on behalf of industry in relation to these rules.

Although US and EU rules are becoming increasingly aligned, they also diverge in many ways and may not give the same answer to a particular question. This is particularly relevant to international businesses where the rules of more than one jurisdiction may be triggered. Because of the high frequency of rulemakings in this area, Russia sanctions developments should be closely monitored on an ongoing basis and advice should be sought in difficult cases.

Please click on the resources link below for a collection of information relating to Russia sanctions and our commentary on Russia sanctions developments.

Resources 

US Resources

US Specially Designated Nationals List (SDN)

Ukraine Sanctions
12 Dec 2014 Ukraine Freedom Support Act of 2014, H.R. 5859
18 Dec 2014 Signing Statement by President Obama on the Ukraine Freedom Support Act
06 Mar 2014 Executive Order 13660, “Blocking Property of Certain Persons Contributing to the Situation in Ukraine”
16 Mar 2014 Executive Order 13661, “Blocking Property of Additional Persons Contributing to the Situation in Ukraine”
20 Mar 2014 Executive Order 13662, “Blocking Property of Additional Persons Contributing to the Situation in Ukraine”
12 Sep 2014 OFAC Implementing Regulations under E.O. 13660 – 13662, 31 C.F.R. § 589
OFAC Sectoral Sanctions Directives under E.O. 13660 – 13662 – Directive 1, as amended
OFAC Sectoral Sanctions Directives under E.O. 13660 – 13662 - Directive 2, as amended
OFAC Sectoral Sanctions Directives under E.O. 13660 – 13662 - Directive 3
OFAC Sectoral Sanctions Directives under E.O. 13660 – 13662 – Directive 4
12 Sept 2014 OFAC Current List of Sectoral Sanctions Identifications (SSI) pursuant to E.O. 13660 –  13662
OFAC “Frequently Asked Questions” Related to Sectoral Sanctions under Executive Order 13662

OFAC General Licenses

OFAC Resource Center for Ukraine/Russia-related Sanctions

Crimea Sanctions
19 Dec 2014 Executive Order 13685, “Blocking Property of Certain Persons and Prohibiting Certain Transactions With Respect to the Crimea Region of Ukraine”

EU Resources

EU Consolidated List of Sanctions Targets

Ukraine Sanctions

25 Sep 2015
European Commission Guidance Notice on Regulation 833
31 Jul 2014 Consolidated Regulation 833/2014
17 Mar 2014 Consolidated Regulation 269/2014
05 Mar 2014 Consolidated Regulation 208/2014

Crimea Sanctions

23 Jun 2014 Consolidated Regulation 692/2014
05 May 2009 Consolidated EU “dual-use goods” Regulation 428/2009

Council Decisions

14 Apr 2014 Council Decision 2014/215/EU on providing macro-financial assistance to Ukraine
23 Jun 2014 Consolidated Council Decision 2014/386/CFSP on restrictions on goods originating in Crimea or Sevastopol, in response to the illegal annexation of Crimea and Sevastopol
31 Jul 2014 Consolidated Council Decision 2014/512/CFSP on restrictive measures in view of Russia's actions destabilising the situation in Ukraine
17 Mar 2014 Council Decision 2014/145/CFSP on restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine

 

UK Resources

HM Treasury’s Consolidated List of Sanctions Target

Ukraine Sanctions
08 Dec 2014 The Ukraine (European Union Financial Sanctions) (No.3) (Amendment No.2) Regulations 2014
15 Sep 2014 The Ukraine (European Union Financial Sanctions) (No.3) (Amendment) Regulations 2014
01 Aug 2014 The Ukraine (European Union Financial Sanctions) (No.3) Regulations 2014
18 Mar 2014 The Ukraine (European Union Financial Sanctions) No. 2 Regulations 2014
06 Mar 2014 The Ukraine (European Union Financial Sanctions) Regulations 2014

Ukraine Sanctions - Overseas Territories Orders
28 Apr 2014 The Ukraine (Sanctions) (Overseas Territories) (No. 3) Order 2014
28 Apr 2014 The Ukraine (Sanctions) (Overseas Territories) (No. 2) Order 2014
05 Mar 2014 The Ukraine (Sanctions) (Overseas Territories) Order 2014

Crimea Sanctions
29 Nov 2014 The Export Control (Russia, Crimea and Sevastopol Sanctions) (Amendment) Order 2014
26 Nov 2014 The Export Control (Russia, Crimea and Sevastopol Sanctions) Order 2014

Crimea Sanctions - Overseas Territories Orders
05 Nov 2014 The Russia, Crimea and Sevastopol (Sanctions) (Overseas Territories) (Amendment) Order 2014
08 Oct 2014 The Russia, Crimea and Sevastopol (Sanctions) (Overseas Territories) Order 2014