Morgan Lewis US and Russia Sanctions Update
US Crimea Sanctions
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Crimea-focused Executive Order 13685 of Dec. 2014
Bars all new direct or indirect US investments / transactions into Crimea - including for energy sector / offshore
areas
There are also Jan. 2015 BIS rules implementing this EO (see slide 15)
Many Crimea-related SDN designations (entities and individuals) from 2014 to date (slide 40)
And March 2020 voluntary disclosure by Swedbank of Crimea-related USD transfers by its Baltic affiliates
And these recent OFAC settlement agreements for Crimea-related sanctions violations
Feb. 2021 one with a US digital currency payment processing company
July 2020 one with world-leading US-based e-commerce co. re business with Crimea etc.
And see July 2015 OFAC Advisory Release re circumvention / evasion by omitting critical information in
financial and trade transactions (further to the EO)
OFAC warns re
various patterns / practices in financial transactions that hinder correspondent banks' efforts to identify and interdict
(note the very substantial fines suffered in recent years by various European banks for similar-type violations of OFAC
sanctions-against countries other than Russia / Crimea)
and similar practices in trade transactions - incl. in distributorship arrangements covering Russia
and OFAC advises various types of mitigation measures for these risks
Note also these OFAC Crimea-related General License exceptions, including:
No. 4 of Dec. 2014, permitting various food and agricultural products (including soft drinks, cigarettes, etc.) and
medicines, medical supplies and devices
No. 9 of May 2015, permitting common internet communications (see related OFAC FAQ 454)
Further SDN designations (somewhat coordinated w/Canada and EU) following 2018 Kerch Strait
Ukraine/Russia navies incident: in Sept. 2019, of 3 officers and 5 vessels of already blacklisted Sovfracht and
its front co. Maritime Assistance; and in Jan. 2020 (slide 40)
Morgan Lewis
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