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OFAC takes the first shot: New Ukraine/Russia-related Executive Order, 6 new General Licenses

These actions were announced earlier today, prior to President Putin’s recognition of the Russian-controlled sections of the Donbas as independent…

The new Executive Order says, among other things, the following:

Section 1. (a) The following are prohibited:

(i) new investment in the so-called DNR or LNR regions of Ukraine or such other regions of Ukraine as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State (collectively, the “Covered Regions”), by a United States person, wherever located;

(ii) the importation into the United States, directly or indirectly, of any goods, services, or technology from the Covered Regions;

(iii) the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of any goods, services, or technology to the Covered Regions; and

(iv) any approval, financing, facilitation, or guarantee by a United States person, wherever located, of a transaction by a foreign person where the transaction by that foreign person would be prohibited by this section if performed by a United States person or within the United States.

Sec. 2. (a) All property and interests in property that are in the United States, that hereafter come within the United States, or that are or hereafter come within the possession or control of any United States person (including any foreign branch) of the following persons are blocked and may not be transferred, paid, exported, withdrawn, or otherwise dealt in: any person determined by the Secretary of the Treasury, in consultation with the Secretary of State:

(i) to operate or have operated since the date of this order in the Covered Regions;

(ii) to be or have been since the date of this order a leader, official, senior executive officer, or member of the board of directors of an entity operating in the Covered Regions;

(iii) to be owned or controlled by, or to have acted or purported to act for or on behalf of, directly or indirectly, any person whose property and interests in property are blocked pursuant to this order; or

(iv) to have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, any person whose property and interests in property are blocked pursuant to this order.

And there are 6 new General Licenses:

  • GL 17 – Authorizing the Wind Down of Transactions Involving the So-called Donetsk People’s Republic or Luhansk People’s Republic Regions of Ukraine
  • GL 18 – Authorizing the Exportation or Reexportation of Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates to Certain Regions of Ukraine and Transactions Related to the Coronavirus Disease 2019 (COVID-19) Pandemic
  • GL 19 – Authorizing Transactions Related to Telecommunications and Mail
  • GL 20 – Official Business of Certain International Organizations and Entities
  • GL 21 – Authorizing Noncommercial, Personal Remittances and the Operation of Accounts
  • GL 22 – Authorizing the Exportation of Certain Services and Software Incident to Internet-Based Communications

Links:

Executive Order

Ukraine General Licenses – 17, 18, 19, 20, 21, 22

Categories: Executive Orders Licenses OFAC Updates Russia sanctions Ukraine sanctions

eric9to5

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