News 09 Apr. 2024
Curtis Announces New Partners and Counsels Across Offices in Spring 2024
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News 25 Jan. 2024
Counsel Mohannad A. El Murtadi Suleiman Addresses “Africanization” of International Investment Law
Event 18 Aug. 2023
Partner Borzu Sabahi Speaks at FDI Moot Shenzhen
News 25 Jul. 2023
Partner Eric Gilioli Ranked in Top 10 Influential Energy & Natural Resources Lawyers in Kazakhstan in Business Today
Client Alert 28 Dec. 2023
U.S. to Impose Secondary Sanctions on Non-U.S. Banks For Financing Russia’s Defense Industry
News 28 Aug. 2024
Curtis Recognized for Excellence in Arbitration in Chambers Latin America Guide 2025
Event 22 Aug. 2023
Partner Dr. Claudia Frutos-Peterson to Speak at Arbitration and ADR Commission of the ICC Mexico
News 15 Aug. 2023
Legal Reader Publishes Article on Dr. Majed Alotaibi’s Arrival as Senior Counsel in Curtis’ Riyadh Office
News 31 Jul. 2023
Curtis Welcomes Senior Saudi Advisor, Dr. Majed Alotaibi, to its Riyadh Office
News 24 Aug. 2023
Curtis Attorneys Quoted in CoinDesk on FTX Founder Sam Bankman-Fried’s Strategy Ahead of His Criminal Trial
Client Alert 10 Jul. 2024
EU Adopts New Restrictive Measures Against Belarus
Client Alert 26 Jun. 2024
The EU Adopts its 14th Sanctions Package Against Russia
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Curtis Attorneys Featured in IBA Insolvency and Arbitration Working Group’s New Reports
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Fernando Tupa to Speak on Indirect Expropriation at Investment Arbitration Seminar organized by the Instituto Peruano de Arbitraje
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.
Economic Sanctions
International Trade
Daniel Porter
Partner
Elena Klonitskaya
Ana Amador
Associate
Marwa Farag
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client alert
EU and the UK Impose Further Sanctions on Russia
OFAC Imposes Sanctions on Russian Persons, Entities, and Vessels
U.S. Congress Nearing Vote on Russia Sanctions Package
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