The Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury issued new Ukraine-Related Sanctions Regulations, 31 CFR part 589, to implement Executive Order 13660 of March 6, 2014 (“Blocking Property of Certain Persons Contributing to the Situation in Ukraine”), Executive Order 13661 of March 17, 2014 (“Blocking Property of Additional Persons Contributing to the Situation in Ukraine”), and Executive Order 13662 of March 20, 2014 (“Blocking Property of Additional Persons Contributing to the Situation in Ukraine”).  These regulations were published as a final rule at 79 FR 26365 on May 8, 2014.  The Ukraine-Related Sanctions apply to U.S. persons, which is defined as “any United States citizen, permanent resident alien, entity organized under the laws of the United States or any jurisdiction within the United States (including foreign branches), or any person in the United States.”  31 CFR s. 589.312.

In keeping with its usual practice, OFAC published the regulations in abbreviated form at this time but intends to supplement part 589 with a more comprehensive set of regulations, which may include additional interpretive and definitional guidance and additional general licenses and statements of licensing policy.  We will continue to monitor the development of the Ukraine-Related Sanctions Regulations at www.InsureReinsure.com.