U.S. Imposes Comprehensive Sanctions Against Crimea

On December 19, 2014, in response to the situation in Crimea, President Obama issued a new Executive Order imposing comprehensive sanctions against the Crimea region of Ukraine, which is currently held by Russia. The Executive Order prohibits:

• new investment in Crimea by a United States person, wherever located;
• the importation into the United States, directly or indirectly, of any goods, services, or technology from Crimea;
• the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of any goods, services, or technology to Crimea; and
• any approval, financing, facilitation, or guarantee by a United States person, wherever located, of a transaction by a foreign person where the transaction by that foreign person would be prohibited by this section if performed by a United States person or within the United States.

As a practical matter, this prohibits all transactions with Crimea within U.S. jurisdiction, including U.S. dollar transactions clearing through the U.S. financial system.