OFAC Gives US Investors, Traders a Month to Wrap Up Dealings with Crimea
The Office of Foreign Assets Control authorized U.S. companies to wind down most divestment and dealings with Crimean individuals and entities through Jan. 31 (here), following recent executive action to quash imports from and exports to Crimea. According to the Dec. 30 OFAC general license, transactions and other dealings will be given the month buffer if they are “ordinarily incident and necessary” to the following criteria:
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- the winding down or divestiture or transfer to a foreign person of a U.S. person's share of ownership, including an equity interest, in pre-Dec. 20, 2014 investments located in the Crimea region of Ukraine
- the winding down of operations, contracts, or other agreements that were in effect prior to Dec. 20, involving the exportation, reexportation, sale, or supply of goods, services, or technology to the Crimea region of Ukraine
- the winding down of operations, contracts, or other agreements that were in effect prior to Dec. 20, involving the importation of any goods, services, or technology from the Crimea region of Ukraine into the United States
President Barack Obama recently banned all trade with Crimea (see 1412190048). Russia militarily absorbed the Crimea peninsula in mid-March after months of insecurity and political unrest in Ukraine. CBP issued guidelines for the sanctions on Dec. 29 (see 1412290005).
OFAC’s general license does not authorize new imports from and exports, reexports or sales to Crimea, and does not allow any trade prohibited under the executive order. Following the Jan. 31 cutoff, OFAC is also requiring U.S. individuals and entities to outline the efforts made to divest and cut off other dealings in a report due 10 business days following Jan. 31.