The United States Office of Foreign Assets Control (OFAC) has issued a Crimea Sanctions Advisory to highlight some of the practices that have been used to circumvent or evade U.S. sanctions involving the Crimea region of Ukraine (Crimea).
Executive Order 13685 (“Blocking Property of Certain Persons and Prohibiting Certain Transactions With Respect to the Crimea Region of Ukraine”) prohibits virtually all direct and indirect transactions (including financial, trade, and other commercial transactions) by U.S. persons or within the United States to or from Crimea unless authorized by OFAC or exempted by statute.
The evasive practices identified by OFAC include the omission or obfuscation of references to Crimea and locations within Crimea in documentation underlying transactions involving U.S. persons or the United States. U.S. persons and persons conducting business in or through the United States should be aware of these practices in order to implement appropriate controls, commensurate with their OFAC sanctions risk profile, to ensure compliance with their OFAC obligations.
The Advisory is a reminder of the importance to comply with any and all applicable sanctions legislation not only involving Crimea but any country and can be found below.
Member Alert is published by The Swedish Club as a service to members. While the information is believed correct, the Club cannot assume responsibility for completeness or accuracy.