Continuing its targeted response to the situation in Ukraine, the U.S. Treasury Department added seven separatist leaders from Russia and Ukraine to its Specially Designated Nationals (“SDN”) List on Friday. All of those persons designated are individuals, although any entities they own or control will also be blocked under the designations.
The designations were made under Executive Order 13660, which the President issued on March 10, 2014. The Executive Order 13660 targets, among others, persons who are responsible for actions or policies that undermine democratic processes or institutions in Ukraine or that threaten the peace, security, stability, sovereignty or territorial integrity of Ukraine, or who are leaders of entities that engage in such activity.
According to the U.S. Treasury Department, the designated individuals “contributed to attempts to illegally undermine the legitimate government in Kyiv, notably by falsely proclaiming leadership positions and fomenting violent unrest.” The individuals are:
- Vyacheslav Ponomaryov, the former self-proclaimed “people’s mayor” of Slovyansk, one of the centers of the separatist movement;
- Denis Pushilin, a leader of a group calling itself the “Donetsk People’s Republic”;
- Andrey Purgin, the self-described co-head of a council running the separatist government in Donetsk;
- Igor Girkin (also known as Igor Strelkov), the self-described “commander-in-chief of the Donetsk People’s Republic” who controls a group of armed separatists in Slovyansk;
- Valery Bolotov, the self-proclaimed governor of the separatist-controlled Luhansk region;
- Sergei Menyailo, the de facto “acting governor” of Sevastopol; and
- Valery Kaurov, the self-described “president of Novorossiya.”
All of the individuals except for Kaurov were already targeted by European Union sanctions. This is a further example of the ongoing coordination between the United States, EU and NATO on the response to the Ukrainian situation.
These designations against political actors likely will not have significant practical effects on trade with Ukraine and Russia. However, companies should ensure compliance with existing Office of Foreign Assets Control restrictions and continue to prepare for escalating sanctions.
We have previously covered Ukraine-related sanctions, including designations of individuals and entities in Ukraine and Russia, in alerts in March (available here and here) and April (available here).
If you have any questions concerning these developing issues, please do not hesitate to contact any of the following Paul Hastings Washington, D.C. lawyers:
Download a PDF of the Client Alert
Paul Hastings LLP
StayCurrent is published solely for the interests of friends and clients of Paul Hastings LLP and should in no way be relied upon or construed as legal advice. The views expressed in this publication reflect those of the authors and not necessarily the views of Paul Hastings. For specific information on recent developments or particular factual situations, the opinion of legal counsel should be sought. These materials may be considered ATTORNEY ADVERTISING in some jurisdictions. Paul Hastings is a limited liability partnership. Copyright © 2014 Paul Hastings LLP.
IRS Circular 230 Disclosure: As required by U.S. Treasury Regulations governing tax practice, you are hereby advised that any written tax advice contained herein or attached was not written or intended to be used (and cannot be used) by any taxpayer for the purpose of avoiding penalties that may be imposed under the U.S. Internal Revenue Code.