12.23.14
by

December 19, 2014: Lots of OFAC Ukraine changes

Ending the year with a bang, President Obama issued a new Executive Order on Friday relating to the Ukraine-related sanctions program, specifically adding new prohibitions relating to Crimea:

  (i)    new investment in the Crimea region of Ukraine by
a United States person, wherever located;
     (ii)   the importation into the United States, directly or
indirectly, of any goods, services, or technology from the
Crimea region of Ukraine;
     (iii)  the exportation, reexportation, sale, or supply,
directly or indirectly, from the United States, or by a
United States person, wherever located, of any goods, services,
or technology to the Crimea region of Ukraine; and
     (iv)   any approval, financing, facilitation, or guarantee
by a United States 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
United States person or within the United States.
     (b)  The prohibitions in subsection (a) of this section
apply except to the extent provided by statutes, or in
regulations, orders, directives, or licenses that may be issued
pursuant to this order, and notwithstanding any contract entered
into or any license or permit granted prior to the effective
date of this order.

This brings the US sanctions focus more in line with the EU, which has always had more of a Crimea focus than a general one against Russian meddling in Ukraine.

Secondly, General License 4 was released, which generally (other than Export Administration Regulation restrictions) allows the export of agricultural commodities, medicine, medical supplies and replacement parts for the medical supplies to Crimea. What is excluded?

(4) Excluded agricultural commodities. Paragraph (a)(1) of this general license does not
authorize the exportation or reexportation of the following items: castor beans, castor bean
seeds, certified pathogen-free eggs (unfertilized or fertilized), dried egg albumin, live animals
(excluding live cattle), embryos (excluding cattle embryos), Rosary/Jequirity peas, non-food-
grade gelatin powder, peptones and their derivatives, super absorbent polymers, western red
cedar, or all fertilizers.

(5) Excluded medicines. Paragraph (a)(1) of this general license does not authorize the
exportationorreexportationofthefollowingmedicines: non-NSAIDanalgesics,cholinergics,
anticholinergics, opioids, narcotics, benzodiazapenes, and bioactive peptides.

(b) Other excluded items.

(1) Agricultural commodities. For the purposes of this general license, agricultural
commodities do not include furniture made from wood; clothing manufactured from plant or
animal materials; agricultural equipment (whether hand tools or motorized equipment);
pesticides, insecticides, or herbicides; or cosmetics (unless derived entirely from plant materials).

(2) Medicine. For the purposes of this general license, medicine does not include
cosmetics.

Finally, the following persons:

ANTYUFEYEV, Vladimir (a.k.a. ALEXANDROV, Vladimir Gheorghievici; a.k.a. ANTIUFEEV, Vladimir Iurievici; a.k.a. ANTIUFEYEV, Vladimir; a.k.a. ANTYUFEYEV, Vladimir Yuryevich; a.k.a. SHEVTSOV, Vadim; a.k.a. SHEVTSOV, Vadim Gheorghievici; a.k.a. SHEVTSOV, Vladimir); DOB 19 Feb 1951; POB Novosibirsk, Russia (individual) [UKRAINE-EO13660].
BEREZIN, Fedor (a.k.a. BEREZIN, Fyodor; a.k.a. BEREZIN, Fyodor Dmitrievich); DOB 07 Feb 1960; POB Donetsk, Ukraine (individual) [UKRAINE-EO13660].
BEZLER, Igor Nikolayevich (a.k.a. BEZLER, Igor; a.k.a. BEZLER, Igor Mykolaiovych; a.k.a. BEZLER, Ihor); DOB 1965 (individual) [UKRAINE-EO13660].
GUBAREV, Pavel (a.k.a. HUBARYEV, Pavlo); DOB 10 Feb 1983; POB Sievierodonetsk, Ukraine (individual) [UKRAINE-EO13660].
KARYAKIN, Alexei Vyacheslavovich (a.k.a. KARIAKIN, Aleksey; a.k.a. KARYAKIN, Aleksey; a.k.a. KARYAKIN, Alexei); DOB 07 Apr 1980; POB Stahanov, Luhansk Oblast, Ukraine (individual) [UKRAINE-EO13660].
KHRYAKOV, Alexander (a.k.a. KHRYAKOV, Aleksandr Vitaliyovych; a.k.a. KHRYAKOV, Alexander Vitaliyovych; a.k.a. KHRYAKOV, Alexandr; a.k.a. KHRYAKOV, Oleksandr; a.k.a. KHRYAKOV, Oleksandr Vitaliyovych), Donetsk, Ukraine; DOB 06 Nov 1958; POB Donetsk, Ukraine (individual) [UKRAINE-EO13660].
KOZITSYN, Nikolai (a.k.a. KOZITSYN, Mykola; a.k.a. KOZITSYN, Mykola Ivanovych; a.k.a. KOZITSYN, Nikolay); DOB 20 Jun 1956; POB Donetsk Region; citizen Russia (individual) [UKRAINE-EO13660].
MALOFEYEV, Konstantin (a.k.a. MALOFEEV, Konstantin Valerevich; a.k.a. MALOFEEV, Konstantin Valerievich); DOB 03 Jul 1974; POB Pushchino, Moscow, Russia; Managing Partner of Marshall Capital Partners (individual) [UKRAINE-EO13660] (Linked To: MARSHALL CAPITAL PARTNERS).
MOZGOVOY, Aleksey (a.k.a. MOZGOVOI, Aleksei; a.k.a. MOZGOVOI, Alexei; a.k.a. MOZGOVOI, Oleksiy; a.k.a. MOZGOVOY, Aleksei; a.k.a. MOZGOVOY, Alexei; a.k.a. MOZGOVOY, Oleksiy; a.k.a. MOZGOVY, Aleksei; a.k.a. MOZGOVY, Oleksiy; a.k.a. MOZHOVVY, Oleksiy; a.k.a. MOZHOVY, Aleksei; a.k.a. MOZHOVY, Oleksiy; a.k.a. MOZHOVYY, Aleksei), Luhansk, Ukraine; DOB 03 Apr 1975; POB Nyzhnya Duvanka, Ukraine (individual) [UKRAINE-EO13660].
NEKLYUDOV, Dmitry Sergeyevich (a.k.a. NEKLYUDOV, Dmitriy Sergeyevich); DOB 17 Feb 1969; POB Simferopol, Ukraine (individual) [UKRAINE-EO13660].
PLOTNITSKY, Igor Venediktovich (a.k.a. PLOTNITSKY, Igor); DOB 24 Jun 1964; POB Kelmentsi, Ukraine (individual) [UKRAINE-EO13660].
POKLONSKAYA, Natalia Vladimirovna (a.k.a. POKLONSKA, Natalya; a.k.a. POKLONSKAYA, Natalia; a.k.a. POKLONSKAYA, Natalya); DOB 18 Mar 1980; POB Eupatoria, Ukraine; Prosecutor of Crimea (individual) [UKRAINE-EO13660].
RUDENKO, Miroslav Vladimirovich (a.k.a. RUDENKO, Miroslav; a.k.a. RUDENKO, Myroslav), Donetsk, Ukraine; DOB 21 Jan 1983; alt. DOB 1983; POB Debaltsevo, Donetsk Region, Ukraine (individual) [UKRAINE-EO13660].
SAVCHENKO, Petr (a.k.a. SAVCHENKO, Peter; a.k.a. SAVCHENKO, Peter A.; a.k.a. SAVCHENKO, Petro Oleksiiovych), Makeyevka, Ukraine; DOB 23 Feb 1968 (individual) [UKRAINE-EO13660] (Linked To: PROFAKTOR, TOV).
TSARYOV, Oleh Anatolievich (a.k.a. TSAREV, Oleg; a.k.a. TSARIOV, Oleh; a.k.a. TSAROV, Oleg; a.k.a. TSARYOV, Oleh), Stari Kodaky, Dnepropetrovsk Oblast, Ukraine; DOB 02 Jun 1970; POB Dnepropetrovsk, Ukraine (individual) [UKRAINE-EO13660].
ZAKHARCHENKO, Alexander; DOB 1976; POB Donetsk, Ukraine (individual) [UKRAINE-EO13660].
ZALDOSTANOV, Aleksandr (a.k.a. ZALDASTANOV, Aleksandr Sergeevich; a.k.a. ZALDOSTANOV, Alexander; a.k.a. ZALDOSTANOV, Alexander Sergeyevich; a.k.a. “Khirurg”; a.k.a. “The Surgeon”); DOB 19 Jan 1963; POB Kirovograd, Ukraine (individual) [UKRAINE-EO13660].

and entities:

DONBASS PEOPLE'S MILITIA (a.k.a. PEOPLE'S MILITIA OF DONBASS), Prospect Zasyadko.13, Donetsk, Ukraine; Email Address voenkom.dnr@mail.ru; alt. Email Address mobilisation@novorossia.co; alt. Email Address novoross24@mail.ru [UKRAINE-EO13660].
MARSHALL CAPITAL PARTNERS (a.k.a. MARSHALL CAPITAL), 5th Floor, Novinsky Passage Business Center, 31 Novinsky Boulevard, Moscow 123242, Russia; Website http://www.marcap.ru; Email Address info@marcap.ru [UKRAINE-EO13660].
NIGHT WOLVES (a.k.a. MOLODEZHNAYA AVTONOMNAYA NEKOMMERCHESKAYA ORGANIZATSIYA NOCHNYE VOLKI; a.k.a. NOCHNIYE VOLKI; a.k.a. NOCHNYE VOLKI), Nizhnije Mnevniki, 110, “Bike Center”, Moscow, Russia; 110 Nizhniye Mnevniki, Moscow, Russia; 110 Nizhnie Mnevniki Ul., Moscow 123423, Russia; Registration ID 1037717009846; Government Gazette Number 14188237 [UKRAINE-EO13660].
NOVOROSSIYA PARTY (a.k.a. NEW RUSSIA PARTY), Ukraine [UKRAINE-EO13660].
OPLOT, Donetsk, Ukraine; Kharkiv, Ukraine [UKRAINE-EO13660].
PROFAKTOR, TOV (a.k.a. PROFAKTOR, LLC), Bud, 22/28, vul. Dzerzhynskogo, Makiivka 86100, Ukraine; Makeevka str., Donetsk Region 86157, Ukraine; Government Gazette Number 32084605 [UKRAINE-EO13660].
SOUTH-EAST MOVEMENT (a.k.a. SOUTHEAST MOVEMENT; a.k.a. YUGO-VOSTOK MOVEMENT), Ukraine [UKRAINE-EO13660].

have been added to the SDN List under the Ukraine-related sanctions program.

Links:

OFAC Notice

Executive Order

General License 4

 

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