Goltsblat BLP advises that, on 3 March 2015, the US President extended for one year the US economic sanctions targeted at particular persons from the Russian Federation and Ukraine.
Extension of the sanctions programme established under Executive Orders No. 13660 dated 3 March 2014, No. 13661 dated 17 March 2014, No. 13662 dated 20 March 2014 and No. 13685 dated 19 December 2014 has been stipulated by a notice signed by the US President (“Notice”). Statements similar to the Notice are periodically issued for other US sanctions programmes (Iran, Syria, Sudan, etc.).
The Notice refers only to the Executive Orders listed above. However, the Directives issued by the Office of Foreign Assets Control (OFAC) under Executive Order 13662, which are implementing the sectoral sanctions envisaging debt and equity finance and oil projects restrictions, as well as restrictions directed at the territories of the Crimean Peninsula and targeted at the Russian companies are extended automatically.
Even so, particular items of the sanctions programme can be altered by US President Executive Orders and many such items can be clarified or interpreted by OFAC. Consequently, a number of state bodies and officials are involved in sanction implementation. However, while managing this process, the US Presidential Administration effectively acts as the sole body either via Presidential powers or via US executive branch agencies.
Sanctions may be altered or lifted, wholly or partially, by repealing Executive Orders or Directives, by issuing General Licences or by removing particular companies from the SSI or SDN lists. Similarly, they can be strengthened, or new companies can be added to the sanction lists.
We will be closely monitoring any changes related to the sanctions programmes targeted at Russia and Ukraine and will keep you updated on any major developments.
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