The EU, US and Russia have taken further steps in response to continuing events in Ukraine.
On 20 March 2014, the US imposed an asset freeze and visa ban on 20 additional individuals and one Russian Bank. A new executive order was also signed to allow the imposition of further restrictions. Russia imposed sanctions against nine US officials in response. The following day, on 21 March 2014, an EU Regulation came into force increasing the number of individuals subject to an asset freeze and travel ban.
Additional US sanctions
On 20 March 2014, the US Office of Foreign Assets Control ("OFAC") announced two escalations in the sanctions it has previously imposed on Russia relating to the situation in Crimea: (a) additional designations of Russian officials and one Russian bank; and (b) the introduction of a new Executive Order allowing the imposition of further sanctions.
Addition of Russian officials and one bank to asset freeze and visa ban
The new designations impose an asset freeze and visa ban on 16 Russian government officials, four individuals described as members of the Russian leadership's inner circle, and one bank (Bank Rossiya) under Executive Order 13661 which authorises sanctions on officials of the Russian government and any individual or entity owned or controlled by, acting for or on behalf of, or providing support to senior Russian government officials.
Bank Rossiya, together with the 20 individuals will now be regarded as a specially designated national ("SDN"), meaning that any of their assets within the US must be frozen and US persons or entities are prohibited from participating transactions involving the SDNs.
Further details on the restrictions imposed on the SDNs by Executive Order 13661 are contained in our previous briefing.
New Executive Order allowing imposition of further sanctions
Also on 20 March, President Obama announced that he had signed a new Executive Order providing for the imposition of additional sanctions on Russia.
This new Executive Order provides for the identification of further SDNs including those determined by the Secretary of the Treasury, in consultation with the Secretary of State, to operate in particular sectors of the Russian economy. The sectors are to be determined by the Secretary of the Treasury and State but the Executive Order provides that they could include financial services, energy, metals and mining, engineering and defence.
No SDNs have yet been identified under this new Executive Order, however it provides the scope for the US to impose further, wide-ranging sanctions on the Russian economy.
Russia imposes sanctions on US officials
EU expands the list of individuals subject to travel restrictions and an asset freeze
On 21 March, EU Regulation 208/2014 of (the "EU Regulation") was published in the Official Journal and came into force.
The EU Regulation expands the list of individuals subject to travel restrictions and an asset freeze. 12 new individuals are to be sanctioned, bringing the total number of persons subject to sanctions in connection with Ukraine's territorial integrity to 33. More information about the Regulation it implements, Regulation (EU) No 269/2014, and the restrictions it imposes are contained in our previous briefing.