On 21 February, OFAC advised that a new Executive Order blocking property of certain persons and prohibiting certain transactions with respect to continued Russian efforts to undermine the sovereignty and territorial integrity of Ukraine had been signed.  The new EO imposes sanctions in respect of the so-called Donetsk People’s Republic (DNR) and Luhansk People’s Republic (LNR) regions of Ukraine.  It –

  • blocks new investment in the regions;
  • prohibits the importation into the US, directly or indirectly, of any goods, services, or technology from the regions;
  • prohibits the exportation, re-exportation, sale, or supply, directly or indirectly, from the US, or by a US person, wherever located, of any goods, services, or technology to the regions;
  • prohibits any approval, financing, facilitation, or guarantee by a US person, wherever located, of a transaction by a foreign person where the transaction by that foreign person would be prohibited by this section if performed by a US person or within the US; and
  • freezes the assets of any leader, official, senior executive officer, or member of the board of directors of an entity operating in the regions – including any person to have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, any person whose property and interests in property are blocked.

OFAC has also issued 6 General Licenses in connection with these sanctions and dealing with such things as the winding down of operations involving the regions, supplies connected with the Covid pandemic, telecommunications and mail, international organisations, personal remittances and internet communications.

Any modest contributions for my time and ongoing expenses are welcomed!  I have a page where you can do so, and where one-off contributions start as low as $3, at

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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