The European Union (EU) and the United States have now both taken targeted action to address the evolving situation in Ukraine. These measures do not impose restrictions on the country or government as a whole. On 6 March 2014, the EU implemented sanctions that target designated persons in Ukraine but these EU measures do not currently affect overall trade with the country. On the same day, President Obama issued a formal statement and an Executive Order (the Order) giving the administration broad authority to also designate persons who are, among other things, engaging in activities undermining democratic processes or institutions in Ukraine; threatening the peace, security, stability, sovereignty, or territorial integrity of Ukraine; contributing to the misappropriation of state assets of Ukraine; or purporting to assert governmental authority over any part of Ukraine without authorization from the Ukrainian government in Kyiv. To date, the president has not designated any persons or entities under this Order. The U.S. sanctions also do not currently affect overall trade with Ukraine. We have set forth below key elements of these restrictions as well as additional measures under these sanctions.
Based on these new measures, companies should assess their business operations and relationships in Ukraine. In reviewing these activities, companies should determine whether they are engaging in activities or have relationships with these designated persons, including companies owned or controlled by them. For companies with automated screening software solutions, any such persons should be added to your systems and screening filters.
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