Executive order prohibiting imports and exports to Crimea region of Ukraine

President Obama has issued an Executive Order prohibiting certain transactions with the Crimea Region of the Ukraine.

Prohibited are:

  1. The import into the U.S. (directly or indirectly) of any goods, services, or technology from the Crimea region of the Ukraine.
  2. The export, re-export, sale or supply (directly or indirectly) from the U.S, or by a U.S. person (wherever located), of any goods, services, or technology to the Crimea region of the Ukraine.
  3. Any approval, financing, facilitation, or guarantee by a U.S. person (wherever located) of a transaction by a foreign person, where the transaction would be prohibited if performed by a U.S. person or within the U.S.
  4. New Investments in the Crimea region of the Ukraine by a U.S person (wherever located).
    These prohibitions apply except when a license or permit is issued pursuant to this order.

All property and interests in property that are in the U.S., that hereafter come within the U.S., or that are or hereafter come within the possession or control of any U.S. person (including any foreign branch) of certain persons are blocked and may not be transferred, paid, exported, withdrawn, or otherwise dealt in.

Please contact the Office of Foreign Assets Control (OFAC) Compliance at 202-622-2490 with any questions.

This follows similar sanctions taken against Russia by the European Union (UN) which banned all investment in Crimea, as well as exports to Crimea in the energy, transport and telecom sectors.

Questions about this regulatory update may be directed to Livingston’s U.S. Regulatory Affairs group .