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ARTICLE · 20 JUNE 2014

Global Procurement Quarterly - Spring 2014

Morrison Foerster
Morrison Foerster
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For the past several years, U.S. sanctions have focused on Iran and Syria. However, recent events in Ukraine have opened a new front in sanctions enforcement.

United StatesInternational Law
Nicholas Spiliotes
Nicholas Spiliotes
Alistair Maughan
Alistair Maughan
Sarah Wells
Sarah Wells
K. Alyse Latour
K. Alyse Latour
Catherine Chapple
Catherine Chapple
Panagiotis Bayz
Panagiotis Bayz
Felix Helmstädter
Felix Helmstädter
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THE NEW FRONT IN U.S. SANCTIONS: UKRAINE AND RUSSIA

By Nick Spiliotes and Aki Bayz

For the past several years, U.S. sanctions have focused on Iran and Syria. However, the recent events in Ukraine have opened a new front in U.S. sanctions enforcement. In March of this year the President issued three Executive Orders in rapid succession, each expanding the scope of potential sanctions targets. These new sanctions, and anticipated additional sanctions, have raised significant compliance concerns for U.S. companies and for non- U.S. companies that seek to comply with U.S. sanctions.

OFAC Overview

As background, U.S. trade sanctions and economic embargoes are administered by the U.S. Department of the Treasury Office of Foreign Assets Control (OFAC). The OFAC sanctions programs are both country-specific (currently covering Cuba, Iran, Sudan, and Syria) and program-specific (e.g., activities related to terrorism, narcotics trafficking, and proliferation). Under the

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