Blocking Property of Certain Persons and Prohibiting Certain Transactions With Respect to the Crimea Region of Ukraine

This executive order imposes a comprehensive economic embargo on Crimea, prohibiting U.S. persons from new investment, trade, and financial transactions with the region. It also authorizes blocking the assets of individuals and entities operating in Crimea and bars their entry into the United States.

Federal Register Open PDF 79 FR 77357

Impact dates

Dec 19, 2014
EO effective at 3:30 p.m. EST

Key directives

Block all property of persons operating in Crimea (Sec. 2)
Prohibit new investment in Crimea by U.S. persons (Sec. 1(i))
Prohibit import of Crimea goods/services/technology to U.S. (Sec. 1(ii))
Prohibit export of goods/services/technology to Crimea (Sec. 1(iii))
Prohibit facilitation of prohibited transactions by foreign persons (Sec. 1(iv))
Suspend entry of designated persons (Sec. 3)
Prohibit charitable donations to blocked persons (Sec. 4)
No prior notice required for designations (Sec. 9)
Treasury authorized to promulgate implementing regulations (Sec. 10)

Who is ordered

Timeline

Immediate

Prohibitions effective at 3:30 p.m. EST December 19, 2014
Blocking of property and interests for designated persons
Suspension of entry for designated persons

Near term (90d)

Treasury/State Department designations of blocked persons
Implementation of regulations and licensing framework

Long term

Ongoing enforcement and compliance obligations
Potential expansion of sanctions based on policy developments

Risks & tensions

Extraterritorial reach (U.S. persons 'wherever located') creates compliance complexity for multinational corporations
Vague 'operating in' standard for designations grants broad discretion to Treasury/State
No prior notice for blocking raises due process concerns flagged in text
Overlap with existing Russia sanctions (EOs 13660-13662) may create confusion about scope
Humanitarian carve-out limited to U.S. government official business only