On 24 June 2014, the EU demonstrated its willingness to impose further measures as a result of continuing developments in Crimea and Ukraine. Whilst the economic impact of these measures may be limited (see below), they do show that sanctions are very much still on the political agenda, and they emphasise the need for businesses with significant trading or commercial relationships with Crimea, Ukraine or Russia, to continue carefully to monitor the situation.
The specific new measures are (i) a ban from 25 June 2014 on the import into the EU of goods originating in Crimea or Sevastopol, and (ii) a ban on the direct or indirect provision of financing, financial support, insurance or reinsurance related to the import into the EU of goods originating in Crimea or Sevastopol.
There is an exemption for goods which the Ukrainian authorities have confirmed originate from Ukraine and there is also a limited "grandfathering" provision which allows execution (until 26 September 2014) of trade contracts concluded before 25 June 2014 and ancillary contracts necessary for the execution of those trade contracts.
The head of the Crimean State Council's Economic Commission (Vitaly Nakhlupin) has been quoted as saying "I do not envisage any major crisis. I do not even know which economic sector might be affected by it. Most of our exports were to Russia; now this is no longer export but domestic operations". That said, any companies which trade in goods originating in Crimea or Sevastopol (or which believe they may finance or insure companies engaged in such trade) will need to review the new Regulation carefully.
Sanctions continue to be imposed by countries worldwide (for example Australian sanctions were widened further on 19 June 2014) and businesses engaged in trade with Crimea, Ukraine or Russia should ensure that they keep up to date with the complex and shifting landscape.
This is of course a dynamic situation, changing day-by-day and even hourly.