On February 21, 2022, President Biden issued an Executive Order entitled “Executive Order on Blocking Property of Certain Persons and Prohibiting Certain Transactions With Respect to Continued Russian Efforts to Undermine the Sovereignty and Territorial Integrity of Ukraine” in response to continued Russian aggression towards Ukraine. Specifically, the February 22, 2022, Executive Order targets Russia’s “purported recognition of the so-called Donetsk People’s Republic (DNR) or Luhansk People’s Republic (LNR) regions of Ukraine.” The full geographic scope of the DNR and LNR is not defined in the Executive Order, but we anticipate this issue will be further clarified by OFAC in the near future.
To read the full Client Alert, click HERE.