Recently, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) promulgated regulations which formally implement the Ukraine-related sanctions set forth in Executive Orders 13660 (“Blocking Property of Certain Persons Contributing to the Situation in Ukraine”), 13661 (“Blocking Property of Additional Persons Contributing to the Situation in Ukraine”), and 13662 (“Blocking Property of Additional Persons Contributing to the Situation in Ukraine”). OFAC has made numerous designations of entities and individuals under the executive orders, which can be reviewed here.
The new regulations, entitled the Ukraine-Related Sanctions Regulations (URSR) 31 CFR Part 589, have been published in abbreviated form in an effort to provide immediate guidance to the public. OFAC has indicated that it intends to supplement the regulations in the near future with a more comprehensive set of regulations which may include additional guidance on interpretations and definitions, as well as additional general licenses and statements of licensing policy.