On April 11, 2014, the US Office of Foreign Assets Control (“OFAC”) issued further designations under Executive Order 13660 (“EO 13660”). EO 13360, which was signed on March 6, 2014, authorizes the United States to impose sanctions on certain persons if they are found to have engaged in certain actions or policies that contribute to the situation in Ukraine. This round of designations targets six Crimean separatist leaders, one former Ukrainian official, and one entity that is a Crimea-based oil and gas company.
The additional individuals designated on April 11, 2014 are:
- CHALIY, Aleksei Mikhailovich (a.k.a. CHALIY, Aleksei; a.k.a. CHALIY, Aleksei Mikhailovich; a.k.a. CHALIY, Aleksey Mikhailovich; a.k.a. CHALIY, Aleksey Mykhaylovych; a.k.a. CHALIY, Alexei; a.k.a. CHALIY, Mikhailovich Oleksiy; a.k.a. CHALY, Aleksey Mikhailovich; a.k.a. CHALY, Alexei; a.k.a. CHALYI, Aleksei; a.k.a. CHALYI, Aleksiy); DOB 13 Jun 1961; POB Sevastopol, Ukraine; Mayor of Sevastopol; Chairman of the Coordination Council for the Establishment of the Sevastopol Municipal Administration (individual) [UKRAINE].
- MALYSHEV, Mikhail Grigorevich, 15/9 Ulitsa Turgeneva, Apt. 9, Simferopol, Crimea, Ukraine; DOB 10 Oct 1955; POB Simferopol, Crimea; Chair of the Crimea Electoral Commission (individual) [UKRAINE].
- MEDVEDEV, Valery Kirillovich, 22 Ulitsa Oktyarskoi Revolutsii, Building 9, Apt. 14, Sevastopol, Crimea, Ukraine; DOB 21 Aug 1946; POB Russia; Chair of the Sevastopol Electoral Commission (individual) [UKRAINE].
- TEMIRGALIEV, Rustam Ilmirovich; DOB 15 Aug 1976; POB Ulan-Ude, Russia; Deputy Chairman of the Council of Ministers of Crimea; Crimean Deputy Prime Minister (individual) [UKRAINE].
- TSEKOV, Sergey Pavlovich; DOB 28 Sep 1953; POB Simferopol, Crimea, Ukraine (individual) [UKRAINE].
- ZHEREBTSOV, Yuriy Gennadievych (a.k.a. ZHEREBTSOV, Yuriy Gennadyevich; a.k.a. ZHEREBTSOV, Yury), 23 Ulitsa Koltsevaya, Yevpatoria, Crimea, Ukraine; DOB 19 Nov 1969; POB Odessa, Ukraine; Counselor to the Speaker of the Crimean Rada (individual) [UKRAINE].
- ZIMA, Pyotr Anatoliyovych (a.k.a. ZIMA, Petr Anatolyevich; a.k.a. ZYMA, Petro), 18 Ulitsa D. Ulyanova, Apartment 110, Simferopol, Crimea, Ukraine; DOB 29 Mar 1965; POB Russia; Head of the Crimean SBU (Security Service of Ukraine) (individual) [UKRAINE].
The additional entity designated on April 11, 2014 is:
- CHERNOMORNEFTEGAZ (a.k.a. CHORNOMORNAFTOGAZ; a.k.a. NJSC CHORNOMORNAFTOGAZ), Kirova / per. Sovnarkomovskaya, 52/1, Simferopol, Crimea 95000, Ukraine. [UKRAINE].
Chernomorneftgaz, the sole entity blocked under today’s actions, is an offshore oil and gas production company based in Crimea. OFAC has specifically indicated that this designation refers only to the entity in Crimea at the address listed, and does not include its parent company.
All property and interests in property of these individuals and entity within the possession or control of a US Person1 are considered blocked and may not be dealt in. Any entity in which a blocked party holds a 50% or greater ownership interest is itself considered blocked by operation of law. US Persons may not engage in any dealings, directly or indirectly, with designated parties.
More information about EO 13660 can be found here. This EO has been complemented by two other Executive Orders, 13661 and 13662, as well as a bill signed into law by the President on April 3, 2014.
Companies doing business in Russia and Ukraine should monitor closely any measures imposed by the United States to ensure compliance. Penalties for noncompliance are severe. We will continue to track and report on these sanctions developments.