Recently, the tragic event regarding Malaysian Airlines Flight 17 in the Ukraine spurred a reminder about the recent sanctions the U.S. has released against Russia due to continued conflict in the region. These are in addition to sanctions that were already in place; these do not replace or amend prior sanctions. While not everyone may be aware of these new sanctions, they may be affected.
The sanctions prohibit:
- “…transacting in, providing financing for, or otherwise dealing in debt with a maturity of longer than 90 days or equity if that debt or equity is issued after on or after July 16, 2014 by, on behalf of, or for the benefit of the persons operating in Russia’s financial sector named under Directive 1, their property, or their interests in property.”
- “….transacting in, providing financing for, or otherwise dealing in new debt—issued on or after July 16, 2014—of greater than 90 days maturity by, on behalf of, or for the benefit of the persons operating in Russia’s energy sector named under the Directive 2, their property, or their interests in property.”
This is not a blocking action, nor will persons identified in Directives 1 and 2 be added to the Specially Designated Nationals (SDN) list. The action does not require U.S. persons to block the property or interests in property of the entities identified in today’s directives. You can read the list of the “persons” identified here.
Note that these are U.S. sanctions only, as other countries may have their own restrictions. While further action may come about as a result of these recent events, at this time those in the U.S. do not need to proceed with any additional changes. Those outside of the U.S. are encouraged to research if they may be facing any limitations in their respective country.