Ukraine-related Sanctions: New U.S. Statute Creates Secondary Sanctions Targeting Certain Dealings with Russia

On December 13, 2014, the United States Congress passed the Ukraine Freedom Support Act of 2014 (“UFSA”), which President Obama is expected to sign into law within the next few days. UFSA creates a program of secondary sanctions targeting transactions outside U.S. jurisdiction involving any of the following:

• Russian transfers of defense articles to Syria or to entities other than the recognized governments of Ukraine, Moldova, or Georgia;
• Significant investment in Russian Arctic offshore, deepwater, or shale projects for the production of oil; and
• Transactions by foreign financial institutions relating to:
  
  • investment in any Russian Arctic offshore, deepwater, or shale project for the production of oil;
  • any transaction by a U.S.-designated SDN (not including SSILs), beginning 180 days from the date UFSA is signed; or
  • sanctionable arms sales.

We will continue to monitor these developments closely. Please feel free to raise any question you may have with any of your regular contacts at the Firm, or with Paul Marquardt in our Washington office.