Menu Home

EU Ukraine-related sanctions FAQ – Part 3

Financial services measures (Article 5) Emergency funding 13. Q. How should the notion of “emergency funding” under Article 5(3) be understood? A. In situations such as those set out in Article 32(4) of Directive 2014/59/EU (Bank Recovery and Resolution Directive), the exemption for emergency funding under Article 5(3) of the […]

December 19, 2014: Lots of OFAC Ukraine changes

Ending the year with a bang, President Obama issued a new Executive Order on Friday relating to the Ukraine-related sanctions program, specifically adding new prohibitions relating to Crimea: (i) new investment in the Crimea region of Ukraine by a United States person, wherever located; (ii) the importation into the United […]

EU Ukraine-related sanctions FAQ – Part 2

Financial services measures (Article 5) Trade Finance Q. Can EU persons process payments, provide insurance, issue letters of credit, extend loans, to sanctioned entities for non-prohibited exports or imports of goods or non-financial services to or from the Union after 12 September 2014? A. Yes, all of these operations are […]