MARCH 11, 2015

SANCTIONS UPDATE

U.S. Expands -Related Sanctions by Designating Separatists and Their Supporters

In response to the continuing crisis in Ukraine, the U.S. government added to its Specially Designated Nationals List (SDN List) parties that it determined are involved in the conflict in Ukraine. Among those targeted were eight Ukrainian separatists, one pro-separatist Russian entity and its leaders and parties that the U.S. government believes have misappropriated Ukrainian state assets. A particularly notable designation is the Russian National Commercial Bank, which the U.S. government has alleged had no presence in Crimea prior to the vote to secede from Ukraine and which the U.S. government has alleged to be used by and Russian authorities to facilitate incorporation of Crimea into the Russian Federation. These designations follow similar action taken by the European Union and Canada on February 16, 2015.

The Office of Foreign Assets Control designated the following parties:

Individuals

• Sergei Abisov, minister of interior affairs of the Republic of Crimea;

• Serhiy Arbuzov, former First Deputy Prime Minister and former acting Prime Minister of Ukraine;

• , former Prime Minister of Ukraine;

• Raisa Bohatyriova, former Minister of Health of Ukraine;

• , leader of the Eurasian Youth Union;

• Ekaterina Gubareva, former foreign minister of the People’s Republic;

• Yuriy Ivakin, leader of the People’s Republic;

• Pavel Kanishchev, leader of the Eurasian Youth Union;

• Aleksandr Karaman, leader of the Donetsk People’s Republic;

• Oleksandr Khodakovskyy, chief of the Vostok Battalion;

• Andrey Kovalenko, leader of the Eurasian Youth Union;

• Oleg Kozyura, head of the Federal Migration Service of Russia;

• Roman Lyagin, chairman of the Central Election Commission and minister of social and labor policy of the Donetsk People’s Republic; and

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• Serhii Zdriliuk, senior commander and leader of the Donetsk People’s Republic.

Entities

• Eurasian Youth Union, a Russian organization alleged to be involved in recruiting individuals to fight on behalf of the Donetsk People’s Republic and

• Russian National Commercial Bank, a Russian bank operating in the Crimea region of Ukraine.

If you have any questions regarding this update, please contact the Sidley lawyer with whom you usually work, or

Andrew W. Shoyer Robert Torresen Lisa A. Crosby Lana Muranovic Partner Partner Partner Associate +1.202.736.8326 +1.202.736.8570 +1.202.736.8754 +1.202.736.8682 [email protected] [email protected] [email protected] [email protected]

Sidley Economic Sanctions Practice Lawyers in our Sanctions Practice advise companies on the applicability of U.S. sanctions programs to corporate and banking transactions, insurance contracts and the sale of goods and services. We handle license applications for agricultural commodities, medical devices and medicines under the Trade Sanctions Reform and Export Enhancement Act of 2000. We also represent companies in enforcement actions involving U.S. sanctions, assist with internal investigations and the development of compliance programs, and counsel clients on voluntary disclosures. For more information about our Sanctions Practice please contact Lisa Crosby ([email protected], +1.202.736.8754) or Robert Torresen ([email protected], +1.202.736.8570)

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