Morgan Lewis US and Russia Sanctions Update
EU Crimea Sanctions
•
Reg. No. 692/2014 as amended
Bars sale, supply, transfer, export of goods and technology (per this Reg's Annex II) to any Crimean
entity or individual or for use there
Covers oil & gas / other mineral resources and E&P, transport, telecoms, power sectors
And further general ban on financing, corporate acquisitions, JVs, investment in real estate,
construction / engineering services, investment services, tourism services
And see EU Information Note to EU Business Operating and/or Investing in Crimea / Sevastopol
(Joint Working Doc. SWD/2014) of July 2014
As amended August 2014, June 2015 and most recently 25 Jan. 2018
Gives updated summary of restrictions now in effect for EU-connected commercial activity there.
(though no real interpretive guidance)
And EU's Sept. 2017 blacklist reg. (see next slide) amendment to allow member state authorities
to permit certain types of payments to Crimean Sea Ports
Note the still-reverberating 2017 scandal re Siemens gas turbines that found their way to Crimea
(evidently without the company's knowledge and despite its compliance program / efforts)
And NL-based Booking.com's 2018 announced discontinuance of tourist booking for Crimea
Some new EU designations in March 2019 following the Russia-Ukraine Black Sea naval incident,
and in Jan. 2020 in connection with Crimean elections
Morgan Lewis
82View entire presentation