The U.S. government has issued new sanctions limiting commerce with Ukraine, and will soon issue additional sanctions against Russia. These sanctions already affect PMA parts and the new sanctions are likely to also affect PMA parts.
The first Executive Order that was signed this week. It defines the “Covered Regions” as the areas covered by the Donetsk People’s Republic (DNR) and the Luhansk People’s Republic (LNR). It also authorizes the Secretary of the Treasury to identify other parts of Ukraine to be identified as a part of the Covered Regions (typically this would be accomplished through an OFAC rule, so it will be important to watch whether this scope expands to include other parts of Ukraine).
- The Executive Order prohibits investment in the Covered Regions;
- The Executive Order prohibits export (or other sale/supply) to the Covered Regions;
- The Executive Order prohibits import from the Covered Regions;
- The Executive Order prohibits participation by a United States person in a transaction by a foreign person that would have been prohibited in the United States.
Last night, President Biden spoke with President Zelenskyy of Ukraine. In the public statement issued after the call, President Biden said that today he would be “meeting with the Leaders of the G7, and the United States and our Allies and partners will be imposing severe sanctions on Russia.”
The next round of sanctions will probably described businesses and people in Russia with whom business is restricted. One of the areas of potential sanctions that is being discussed in Washington is specific export restrictions on aerospace products and articles.
In addition, Janet Yellen has signed a determination that limits financial transactions with Russia.
MARPA members should be cautious about transactions with Russia and in particular should watch carefully for more export sanctions that may more directly target Russia.
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