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Additional Sanctions Imposed on Crimea

On January 29th, the Commerce Department issued a final rule amending the EAR in light of recent developments in Russia and Ukraine.  With the exception of food or medicine classified as EAR99, all other items falling within the scope of the EAR will require a license for export or reexport to the Crimea region of the Ukraine.

 Additionally, a presumption of denial was instituted for all such exports/reexports, except for items authorized under OFAC General License No. 4 which will be reviewed on a case-by-case basis. These steps are in line with Executive Order 13685 issued in December, which found the recent actions of Russian Federation forces to undermine democracy and stability in the Crimea region and thus be a threat to the national interests of the United States.


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