A review of business and other dealings with parties in Russia and the Ukraine is in order in light of sanctions imposed today by the United States and European Union on eleven and twenty-one, respectively, new Russian and Ukrainian individuals.

Following several weeks of escalating diplomatic tension surrounding the role of Russia in events in Ukraine, and the referendum vote of Crimea on March 16, 2014 to secede from Ukraine and join Russia, the United States and EU today followed through on promises to implement sanctions on certain Russian and Ukrainian officials. These sanctions come on the heels of sanctions already imposed by the EU on eighteen members of the former Ukrainian regime on March 6.

United States Targets Russian and Ukrainian Officials

According to a new Executive Order signed today by President Obama, seven Russian officials are said to have engaged in conduct that “undermine[s] democratic processes and institutions in Ukraine; threaten[s] its peace, security, stability, sovereignty, and territorial integrity; and contribute[s] to the misappropriation of its assets, and thereby constitute[s] an unusual and extraordinary threat to the national security and foreign policy of the United States.”  The targeted Russian officials are either close advisors to President Putin of Russia, or are members of the Russian parliament who have taken steps to support a Crimean secession.

Additionally, using the authority of Executive Order 13660 (E.O. 13660), described in our previous bulletin, sanctions were imposed on four Ukrainians accused of “undermin[ing] democratic processes and institutions in Ukraine; threaten[ing] its peace, security, stability, sovereignty, and territorial integrity; and contribut[ing] to the misappropriation of its assets,” including former Ukrainian president Yanukovych and members of the breakaway Crimean parliament.

Together, the Orders block “[a]ll property and interests in property that are in the United States, that hereafter come within the United States, or that are or hereafter come within the possession or control of any United States person (including any foreign branch).” No blocked property or interests in property of the named individuals may be “transferred, paid, exported, withdrawn, or otherwise dealt in” by US Persons. This includes, but is not limited to:

“(a) the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any person whose property and interests in property are blocked pursuant to this order; and (b) the receipt of any contribution or provision of funds, goods, or services from any such person.” These prohibitions freeze any such assets of the listed individuals and effectively prohibit US Persons from engaging in transactions with the listed individuals. US Persons include permanent resident alien, entity organized under the laws of the United States or any jurisdiction within the United States (including foreign branches), or any person in the United States.

All eleven individuals have been added to the Specially Designated Nationals (SDN) List maintained by the Office of Foreign Assets Control (OFAC) of the Department of Treasury. A copy of these new additions to the SDN List from by both Orders, including alias and birthplace information can be found at: http://www.treasury.gov/ofac/downloads/t11sdnew.pdf.

The Russian individuals designated by the new Executive Order of March 17 are:

  1. Yelena Mizulina [State Duma Deputy, born December 9, 1954]
  2. Leonid Slutsky [State Duma Deputy, born January 4, 1968]
  3. Andrei Klishas [Chairman of the Russian Federation Council Committee on Constitutional Law, Judicial and Legal Affairs and the Development of Civil Society, born November 9, 1972]
  4. Valentina Ivanovna Matviyenko [Federation Council Speaker, born April 7, 1949]
  5. Dmitry Olegovich Rogozin [Deputy Prime Minister of the Russian Federation, born December 21, 1963]
  6. Vladislav Yurievich Surkov [Presidential Aide to the President of the Russian Federation, born September 21, 1964]
  7. Sergey Glazyev [Presidential Advisor to the President of the Russian Federation, born January 1, 1961]

The four Ukrainian individuals designated under E.O. 13660 are:

  1. Sergey Aksyonov [Claims to be the Prime Minister of Crimea and has rejected the authority of the legitimate government in Kyiv, born November 26, 1972]
  2. Vladimir Konstantinov [Speaker of the Crimean parliament, which on March 11, 2014, declared independence from Ukraine, born November 19, 1956]
  3. Viktor Medvedchuk [Alleged to have materially assisted, sponsored, or provided financial, material, or technological support to former president Yanukovych and being a leader of an entity that threatens the sovereignty of Ukraine, born August 7, 1954]
  4. Viktor Yanukovych [Former president of Ukraine, born July 9, 1950]

European Union Adds Russian and Ukrainian Individuals to List of Those Already Sanctioned

The EU first imposed sanctions in the form of asset freezes against eighteen members of former Ukrainian president Yanukovych’s government on March 6. See our previous bulletin for details of those sanctions. Today’s sanctions target officials in the breakaway parliament of Crimea and Russian officials said to have supported attempts to annex Crimea by Russia. The names and identifying information of the twenty-one newly sanctioned individuals can be found in Annex 1 of the new EU Regulation.


Further US and EU designations are anticipated and other nations may join in these sanctions as well. Finally, Russian officials have warned of repercussions in the form of retaliatory sanctions, which have yet to be announced. As events continue to evolve, continued vigilance remains vital.