Treasury Sanctions Individuals and Entities Involved In Sanctions Evasion Related To Russia and Ukraine
On 30 July 2015, the Office of Foreign Assets Control (OFAC) has issued an important Crimea Sanctions Advisory to highlight some of the practices that have been used to circumvent or evade U.S. sanctions involving the Crimea region of Ukraine (Crimea). Executive Order 13685, "Blocking Property of Certain Persons and Prohibiting Certain Transactions With Respect to the Crimea Region of Ukraine" prohibits virtually all direct and indirect transactions (including financial, trade, and other commercial transactions) by U.S. persons or within the United States to or from Crimea unless authorized by OFAC or exempted by statute. The evasive practices identified by OFAC include the omission or obfuscation of references to Crimea and locations within Crimea in documentation underlying transactions involving U.S. persons or the United States. U.S. persons and persons conducting business in or through the United States should be aware of these practices in order to implement appropriate controls, commensurate with their OFAC sanctions risk profile, to ensure compliance with their OFAC obligations.
The action is designed to counter attempts to circumvent U.S. sanctions, to further align U.S. measures with those of its international partners, and to provide additional information to assist the private sector with sanctions compliance.
For the identifying information related to this action, click here.