Under newly adopted EU legislation sanctions have been extended in relation to the Ukraine by adding 14 Ukrainian separatists and 5 high-ranking Russian officials to the existing list of those subject to an asset freeze and visa ban, and, 9 separatist groups have also been added to the existing asset freeze list.
An extension of EU sanctions had been unanimously adopted earlier this February 2015 but their entry into force had been put on hold to allow continued diplomatic efforts to reach a ceasefire agreement for Eastern Ukraine. Although agreement on the ceasefire was reached a week ago the EU has pressed on with the expanded asset freeze because of what the EU considers to be a continuing very serious situation in the Ukraine. The EU considers that the individuals and entities concerned are actively involved in separatist activities in Eastern Ukraine or supporting such activities from Russia.
The effect of the extended asset freeze is that, within EU jurisdiction, all funds and economic resources belonging to or controlled by those listed are frozen, and, funds or economic resources may not be made available, either directly or indirectly, either to or for the benefit of those listed, unless they have been legally licensed.
This latest move may is incremental but acts as a continued reminder for all those doing business with Russia to ensure continued compliance with the sanctions regime and update their risk policies, procedures and risk assessments, especially as non-compliance may lead to financial penalties and in some cases may constitute criminal offences.
We have earlier reported on sanctions here.
André Bywater is a commercial lawyer with Cordery in London where he focuses on regulatory compliance, processes and investigations.
André Bywater, Cordery, Lexis House, 30 Farringdon Street, London EC4A 4HH
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