New Sanctions Hours after Russian Recognition of Sympathetic Regions of Ukraine

The Biden Administration today swiftly implemented broad-reaching sanctions on what it referred to as the “so-called” Donetsk and Luhansk People’s Republics (the DNR and LNR) within Ukraine, hours after Russia recognized these two pro-Russian regions of the country. Specifically, a new Executive Order imposes a near total embargo on these regions akin to what the Obama Administration did with the Crimea following Russia’s invasion in 2014.

The new Executive Order prohibits broad swaths of the two territories and allows for blocking of large groups of people connected with the region.

Following this move, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued 6 new “General Licenses,” or “GLs”authorizing activities such as the sale of agricultural commodities to the two regions as well as continued provisions of internet connectivity and mail services by U.S. persons. General licenses are self-executing, meaning permission for the authorized activities does not require specific licenses from OFAC so long as all activity falls within the rubric of the GL. Nonetheless, those entities operating under the authority of these GLs should exercise caution and vigilance to ensure compliance.

An international trade compliance (sanctions, export controls, customs, anti-corruption) and defense lawyer.

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