On 6 March 2015, the Federal Council decided to extend its measures to prevent the circumvention of international sanctions in view of the situation in Ukraine, The action followed decisions taken by the EU. It added the measures decreed by the EU last December following non-recognition of the annexation of the Crimea and Sevastopol to the ordinance on international sanctions of 27 August 2014. The Federal Council also added to Annex 3 of the ordinance…
On 15 January 2015, the Parliament of Ukraine adopted Law of Ukraine No.126-VIII “On amendments to several Laws of Ukraine regarding abolishing import licensing of active pharmaceutical ingredients” (the Amendment). This Amendment abolishes the requirement to obtain a license to import active pharmaceutical ingredients (APIs), which became effective from 1 January 2015. Import licensing of pharmaceuticals was introduced by Law of Ukraine No. 5038-VI “On amendments to several Laws of Ukraine regarding import licensing…
On March 5, 2015, the Federal Register published Presidential Notice of March 3, 2015 – Continuation of the National Emergency with Respect to Ukraine which extends for an additional year the national emergency first declared on March 6, 2014, by Executive Order (EO) 13660, to deal with the unusual and extraordinary threat to the national security and foreign policy of the United States constituted by the actions and policies of persons that undermine democratic processes…
On 3 February 2015, legislation.gov.uk posted SI 2015/97 – The Export Control (Various Amendments) Order 2015. According to the Explanatory Note accompanying the posting: This Order makes provision for the enforcement of amended trade restrictions against Russia specified in Council Regulation (EU) No 1290/2014 (OJ No L 349, 5.12.2014, p20) which amends Council Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine (OJ No L 229, 31.7.2014,…
On January 30, 2015, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued three Ukraine-related general licenses authorizing certain transactions relating to Crimea that would otherwise be prohibited under Executive Order 13685. As detailed in our recent post, Executive Order 13685 imposed comprehensive sanctions on the Crimea region of Ukraine and provided the authority for blocking certain persons in connection with the situation in Crimea. Consistent with Executive Order 13685, the U.S. Government…
Following the Extraordinary Foreign Affairs Council meeting convened on 29 January 2015, in response to the attacks on the Ukrainian city of Mariupol, the EU has announced that it will extend the designated party controls that were adopted in March 2014 until September 2015. During the official press conference that followed the meeting, High Representative Vice-President Mogherini described the situation on the ground as “extremely worrying and negative”. The Council has called on the High…
Effective from 31 January 2014, the EU has expanded the scope of the designated party controls targeting those considered to be responsible for the misappropriation of Ukrainian State funds to include those subject to investigation by the Ukrainian authorities, specifically for (a) “the misappropriation of Ukrainian public funds or assets or being an accomplice” and (b) “abuse of office as a public office-holder in order to procure an unjustified advantage for him- or herself…
On January 29, 2015, the Bureau of Industry and Security (BIS) published in the Federal Register a final rule amending the Export Administration Regulations, 15 C.F.R. Part 730 et seq. (EAR), to impose a license requirement on the export, reexport, or transfer by any person of virtually all “items subject to the EAR” to or within the Crimea region of Ukraine. The final rule came into effect upon publication in the Federal Register. It is…
On December 30, 2014, the Office of Foreign Assets Control (OFAC) published General License No. 5 Authorizing Certain Activities Prohibited by Executive Order 13685 of December 19, 2014 Necessary to Wind Down Operations Involving the Crimea Region of Ukraine. Except as provided in paragraph (b) of the general license (GL5), it authorizes, through 12:01 a.m. EDT, February 1, 2015, all transactions and activities prohibited by Section 1 of Executive Order 13685 of December 19,…
Effective at 3:30 pm on December 19, 2014, President Obama issued an Executive Order that (i) imposes comprehensive sanctions on the Crimea region of Ukraine (“Crimea”), which has been occupied by Russia since March 2014, and (ii) provides the authority for blocking certain persons in connection with the situation in Crimea. OFAC’s announcement is available here. The Executive Order prohibits the following activities: • New investment in Crimea by U.S. Persons (i.e., (i) entities organized under…