News 24 Jun. 2021
Curtis successfully defends foreign states' procedural privileges in the UK Supreme Court
News 23 Jun. 2021
Ibrahim Elsadig joins Curtis as Partner in Dubai
Client Alert 24 Feb. 2022
EU, UK, Japan and Australia Impose Sanctions on Russia
News 09 Aug. 2021
Curtis, Mallet-Prevost, Colt & Mosle enters into association with Chevalier Law in Singapore.
News 06 May. 2022
Curtis Advises Terna Group on the Sale of its Latin America Power Transmission Assets to CDPQ
Publications 05 May. 2022
Marie-Claire Argac, Simon Batifort, and Cyprien Mathié share highlights from “Affaires d’Etats: Practical Considerations When Defending States in International Arbitration” on Kluwer Arbitration Blog
Event 26 Apr. 2022
Claudia Frutos-Peterson Speaks at CAI Costa Rica’s 13th Congress of International Arbitration
News 21 Apr. 2022
SCOTUS Upholds U.S. Colonialism under the U.S. Constitution
Client Alert 23 Mar. 2022
The Dubai International Arbitration Centre (DIAC) has launched the DIAC Arbitration Rules 2022
Event 22 Nov. 2021
Partner Antonia Birt spoke at ADGMAC and AIAC Webinar Series: Webinar 5 - Disputes in Fintech and Complex Technology in MESEA
News 19 May. 2022
Eliot Lauer’s and Juan Perla’s Tenth Circuit Arguments Featured on Audio Arguendo Podcast
News 16 May. 2022
Curtis Files SCOTUS Amicus Brief for Ohio Justice & Policy Center in Prisoners’ Rights Case
Client Alert 21 Apr. 2022
New Laws Targeting Assets of Russian Oligarchs: The U.S. Announces Task Force KleptoCapture and the Kleptocracy Asset Recovery Rewards Program
Client Alert 19 Apr. 2022
U.S. President Biden Expands Export Controls Imposed on Russia and Belarus
Client Alert 24 Jun. 2021
Update on Virtual Notarization (Executive Order 202.7) During the COVID-19 (Coronavirus) Pandemic (Updated: June 24, 2021) — U.S. Insight
Update on Virtual Witnessing (New York Executive Order 202.14) During The COVID-19 (Coronavirus) Pandemic (Updated: June 24, 2021) — U.S. Insight
Client Alert 22 Feb. 2022
The full alert is available for download with footnotes here.
On February 21, 2022, the U.S. President issued an Executive Order (“E.O.”) titled “Blocking Property of Certain Persons and Prohibiting Certain Transactions With Respect to Continued Russian Efforts to Undermine the Sovereignty and Territorial Integrity of Ukraine.” The E.O. is a swift response to a decree issued by the Kremlin on the same day recognizing the sovereignty of two Russia-backed regions in eastern Ukraine: the Donetsk and Luhansk People’s Republics. Russian President Vladimir Putin also ordered Russia’s defense minister to deploy troops in the two regions. The recent events represent a significant escalation of Ukraine-Russia tensions.
The E.O. was issued following Russia’s recognition of the Donetsk People’s Republic (“DNR”) and Luhansk People’s Republic (“LPR”) regions of Ukraine (together, the “Covered Regions”) as sovereign territories. The E.O. notes that Russia’s recognition contradicts its commitments under existing agreements, and further threatens the peace, stability, sovereignty, and territorial integrity of Ukraine, and thereby constitutes an “unusual and extraordinary threat to the national security and foreign policy of the United States.”
The E.O. prohibits investment and trade by U.S. persons to, from, or in the Covered Regions. These sanctions are very similar to the sanctions imposed on Crimea in 2014.
The E.O. blocks all property and interests in property that are in the United States or that come within the possession or control of a U.S. person where that property belongs to any person or entity designated by the U.S. Secretary of Treasury, in consultation with the Secretary of State:
In addition, the E.O. prohibits any “approval, financing, facilitation, or guarantee” by a U.S. person of a transaction performed by a foreign person, if that transaction would be prohibited to a U.S. person.
The E.O. further prohibits any transaction that evades or avoids the prohibitions of the E.O., as well as any conspiracy formed to violate any such prohibition. Moreover, the E.O. imposes a ban on entry into the United States of persons designated under the E.O.
In a statement issued by White House Press Secretary Jen Psaki on February 21, 2022, the White House announced that “these measures are separate from and would be in addition to the swift and severe economic measures we have been preparing in coordination with Allies and partners should Russia further invade Ukraine.” The statement went on to note that “[w]e are continuing to closely consult with Allies and partners, including Ukraine, on next steps and on Russia’s ongoing escalation along the border with Ukraine.”
In parallel with the E.O., the U.S. Department of Treasury's Office of Foreign Assets Control (“OFAC”) issued five General Licenses under its Ukraine program. A general license authorizes a particular type of transaction for a class of persons without the need to apply for a license from OFAC.
We expect further developments in U.S. sanctions.
Attorney advertising. The material contained in this Client Alert is only a general review of the subjects covered and does not constitute legal advice. No legal or business decision should be based on its contents.
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