News Story

Russia/Ukraine: Status of U.S. Sanctions as of 04/04/2014

April 04, 2014

On April 4, President Barack Obama signed into law the United States’ Support for the Sovereignty, Integrity, Democracy, and Economic Stability of Ukraine Act of 2014 (the Act). In essence, the Act codifies the authority of the president to impose future sanctions in connection with the situation in Crimea. It does not automatically result in any new sanctions.

In addition to loan guarantees for Ukraine, notable features of the Act include the following:

  • The Act exempts imports into the United States from sanctions. Thus, it appears that future sanctions imposed under the Act may not prohibit U.S. persons from importing goods, even from sanctioned persons or entities.
  • The Act allows the U.S. authorities to impose future sanctions on a new category of Russian individuals, who are described as including “any official of the Government of the Russian Federation, or a close associate or family member of such an official, that the President determines is responsible for, or complicit in, or responsible for ordering, controlling, or otherwise directing, acts of significant corruption in the Russian Federation, including the expropriation of private or public assets for personal gain, corruption related to government contracts or the extraction of natural resources, bribery, or the facilitation or transfer of the proceeds of corruption to foreign jurisdictions.”

Presumably, this could be used by the U.S. authorities to expand the current list of sanctioned persons. To date, no such decision has been made.

The above is not a comprehensive summary of the Act.