On 18 December 2014, President Obama signed into law the Ukraine Freedom Support Act of 2014 (Public Law No. 113-272) (“UFSA”), which authorises expanded sanctions on Russia. The UFSA, originally introduced in the Senate in September, calls for the expansion of existing US sanctions that target companies in and activities involving Russia’s defence and energy sectors, including non-US financial companies that facilitate and support related transactions. Among other provisions, the sanctions set out in the UFSA include:
- Imposing sanctions on Rosoboronexport, Russia’s state-owned agency for defence-related imports and exports;
- Authorising sanctions on Russian companies that sell or transfer defence articles into certain countries, including Syria, Ukraine, Georgia and Moldova;
- Authorising sanctions on any foreign person that makes a significant investment in certain Russian crude oil projects; and
- Prohibiting foreign financial institutions that facilitate certain transactions involving Russia’s defence and energy sectors or any Russian person on the US Treasury Department’s Specially Designated Nationals list from opening or maintaining correspondent or payable-through accounts in the United States.
In signing the UFSA into law, President Obama indicated that his Administration did not intend to impose new sanctions under the law but noted that “the Act gives the Administration additional authorities that could be utilized, if circumstances warrant.”