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President Obama Imposes Broad Sanctions Framework in Response to Ukraine Crisis Prepare for an Uncertain Future

As part of its response to the unfolding events in Ukraine, on March 6 the White House issued a broad Executive Order authorizing the Treasury Department to impose sanctions on persons or entities found to have ties to the former regime of Viktor Yanukovych, to have participated in efforts to suppress the Kiev uprising, or to be involved in the occupation of Crimea by forces linked to the Russian military. The EU has imposed a freeze on the assets of Yanukovych, certain immediate family members, and officials in this government. The situation in Crimea remains extremely fluid, and the prospect exists for broader sanctions, even against Russian funds, companies, and officials. U.S. and European companies involved in a current or planned investment in Ukraine or Russia, or a transaction with counterparties tied to activities falling within the broader outlines of the U.S. and EU sanctions programs, should engage in an immediate and sober assessment of the risks inherent in continuing the activity.

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