On March 6, 2014, President Obama issued an Executive Order setting forth the foundation for imposing sanctions against any individual or entity responsible for or complicit in actions or policies that undermine democratic processes or institutions in Ukraine or threaten the peace, security, stability, sovereignty, or territorial integrity of Ukraine.  Further, the Executive Order allows for sanctions against persons who are involved in the misappropriation of state assets of Ukraine or have asserted governmental authority over any part or region of Ukraine without the authorization of the Government of Ukraine.  The relevant sanctions include, but are not limited to, asset blocking and the denial of entry into the United States of the persons sanctioned.

The Executive Order was issued in direct response to threats to the peace, security, or stability of Ukraine, as well as efforts to assert governmental authority in the region of Crimea without the authorization of the Government of Ukraine.

The Office of Foreign Assets Control has not yet published a list of individuals or entities for which these sanctions will be imposed.

We will monitor the evolving situation in the Ukraine for its impact on those with business interests in the region.