![]() Under the new Ukraine-related Crimea sanctions executive order persons can be blocked upon a finding by the Secretary of the Treasury, in consultation with the Secretary of State, that the person is: 1) operating in Crimea 2) a leader of an entity operating in Crimea 3) owned or controlled by a person blocked pursuant to the executive order or 4) someone who provides material assistance or goods or services to a person blocked pursuant to the executive order.ģ. Blocking of Those Operating in the Ukraine: While the statutory authority underlying these sanctions, the International Emergency Economic Powers Act (“IEEPA”), does not automatically block persons, the executive order imposing the sanctions does contain a blocking authority. Whether or not such a prohibition will appear in new regulations promulgated pursuant to this executive order is unknown at this time, but it is likely that in the coming weeks we will see new regulations from the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and the United States Department of Commerce Bureau of Industry and Security (“BIS”) which should cover this type of activity.Ģ. Ofac general license iran medical devices license#origin good, service, or technology if that person knows that the export is intended for Iran and the export is subject to export license application requirements. 560.205, which prohibits any person from exporting to Iran a U.S. ![]() persons, and at this time there is no analogous prohibition to that found in the Iranian Transactions and Sanctions Regulations (“ITSR”), 31 C.F.R. It is important to note, however, that these transactions are imposed specifically on U.S. exportation and reexportation of goods, services, and technology to Crimea and facilitation of such prohibited transactions by foreign persons. Persons: The new prohibitions extend to new investment in Crimea importation of Crimean goods, services, or technology into the U.S. While, there will undoubtedly be numerous posts concerning these new sanctions in the future, here are my top three (3) things you need to know about the new trade embargo added to the Ukraine-related sanctions program:ġ. Rather, this is a trade embargo imposed upon the region of Crimea, similar in scope to the kind of trade embargo targeting Iran and Sudan. What is interesting about these new sanctions program is that it’s not the targeted, or even micro-targeted, sanctions we have seen imposed thus far in relation to the situation in the Ukraine. ![]() Obviously these new sanctions are part of the Ukraine-related sanctions program imposed as a result of the Russian Federation’s actions vis-a-vis the Ukraine. Lost in all of last week’s news about Cuba sanctions relaxation, and the hustle and bustle preceding the imminent Christmas holiday, was the issuance of a new comprehensive trade embargo targeting the Crimea. ![]()
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