To help companies as they try to comply with the rapidly expanding sanctions programs being created in the wake of the Crimean crisis, a leading international trade law firm has provided a list online of the growing number of individuals and organizations subject to Ukraine-related economic sanctions imposed by the U.S. as well as Canada, Australia and the EU.
The law firm of Stewart and Stewart will be updating the list, which now totals 69 different persons and organizations sanctioned by one or more of countries. The list is designed to be used in combination with other government maintained lists. The law firm’s list includes known aliases and names of:
- Ukrainian Crimean Separatists
- Ukrainian former government officials and their associates
- Russian government officials and individuals Russian entities
The Stewart and Stewart list also includes background information on all persons named. It is based on documents and official sanction orders from across the globe that began March 6 when President Obama signed an executive order pursuant to the International Emergency Economic Powers Act and other federal statutes.
“Companies dealing with anyone in or from Russia and Ukraine need to be alert to the different lists of persons and organizations subject to varying restrictions under several countries’ newly instituted Ukraine related sanctions,” said Alan Dunn, a partner at the law firm Stewart and Stewart. Dunn is a former assistant commerce secretary who helps companies manage export controls and export licensing.
“Not only are different countries targeting somewhat different people and institutions, they are still adding to their lists and are expected to make additional changes as they coordinate sanctions policies. Companies engaged in commerce with Russians and Ukrainians must stay alert in order to comply with the changing sanctions and avoid potentially severe penalties,” Dunn said.
Economic sanctions like those arising from the Ukraine-Crimean crisis issued by the U.S. federal government are spelled out in the Office of Foreign Assets Control regulations. Dunn noted that U.S. persons engaged in transactions with Ukraine and Russia should closely monitor the Consolidated Export Screening List to ensure they are not engaged in transactions with blocked and denied persons.
- Consolidated Export Screening List: (http://export.gov/ecr/eg_main_023148.asp).
“We expect more companies, entities and individuals will be subjected to sanctions so everyone subject to US jurisdiction should regularly check these lists to make sure persons and entities with whom they are doing business have not become subject to sanctions,” Dunn said.
For more information about Stewart and Stewart, please visit the International Society of Primerus Law Firms.