Ukraine-Related Sanctions: Limited U.S. Sanctions Against Four Russian Energy and Financial Firms; Other

On July 16, 2014, the United States expanded sanctions against Russian entities relating to the Ukrainian crisis. The below memo provides further detail on these developments, and a brief summary is below:

• Entities in the Russian financial and energy sectors have been identified as potential sanctions targets.
• However, only four companies have actually been subjected to limited sanctions: Gazprombank, Vnesheconombank, Novatek, and Rosneft. Transactions with the identified sectors are not generally prohibited.
• These entities are not SDNs subject to full U.S. sanctions. Rather, new long-term debt and (for Gazprombank and VEB only) equity transactions are prohibited within U.S. jurisdiction. Other transactions are unaffected.
• Trading in previously issued debt or equity is not restricted. Derivative transactions involving newly-issued debt or equity as a reference security are also permitted under a general license.
• A number of Russian defense firms, as well as a number of persons and entities said to be linked to separatist activities in Ukraine, have been added to the SDN List and are subject to comprehensive U.S. sanctions.

We will continue to monitor these developments closely. Please feel free to raise any question you may have with any of your regular contacts at the Firm, or with Paul Marquardt in our Washington office regarding U.S. sanctions or with Till Müller-Ibold in our Brussels office or Sunil Gadhia in our London office regarding European sanctions.