On March 6, 2014, President Obama issued an Executive Order imposing sanctions upon persons that undermine democratic institutions and processes in Ukraine or threaten the peace, security, stability, sovereignty and territorial integrity of Ukraine. The Executive Order expressly provides that persons who have asserted governmental authority in the Crimean region without the authorization of the Government of Ukraine are sanctioned persons. The sanctions are effective immediately.

The Executive Order blocks all property and interests in property of a sanctioned person that are in the United States or are in the possession, custody or control of any United States person. Sanctioned persons will also be denied entry to the United States. “United States persons” are defined to include any United States citizen or green card holder, regardless of where they reside; any entity organized under the laws of the United States or any State in the United States, including foreign branches; and any person actually in the United States. A foreign corporation is deemed to be “in the United States” if it has an office in the United States.

The U.S. Department of Treasury, Office of Foreign Assets Control (“OFAC”), in consultation with the U.S. Department of State, will publish and maintain a list of persons sanctioned under the Executive Order. At the time of this writing, no such list has yet been published. It is expected that the list of persons sanctioned under the Executive Order will be included in OFAC’s list of Specially Designated Nationals (the “SDN List”). All United States persons should exercise caution when entering into or continuing any transaction with a person who may be subject to sanction under the Executive Order. The SDN List is updated frequently by OFAC, and may change without prior notice.

The United States also has sanctions in effect with respect to the following countries: Belarus; Burma (Myanmar); Cote d’Ivoire (Ivory Coast); Cuba; Democratic Republic of the Congo; Iran; Iraq; Lebanon; Liberia; Libya; North Korea; Somalia; Sudan; Syria; Yemen; and Zimbabwe. The sanctions range from prohibitions on transactions by United States persons with certain specified individuals to a prohibition against any transactions by any person worldwide with respect to certain countries.