What is the status of the evolving international sanctions against Ukraine and Russia?

1. Since the recent escalation of the Ukraine crisis in March, there have been almost daily developments regarding economic sanctions – ranging from details of implementation to proposals for new or tougher measures.
2. This update is part of a series of snapshots of the current sanctions, how they apply to financial institutions doing business in or with Ukraine and Russia and their customers and counterparties, compliance requirements in different scenarios, and where sanctions might be headed in the near future.

What are the penalties for violating sanctions?

1. US penalties for violations of the sanctions can be severe, including substantial civil and criminal fines and imprisonment.
2. The Executive Orders also establish that the provision of support or services, including financial services, to designated persons is a criterion for potential future designation.
3. In the EU, the competent authorities of the EU Member States are responsible for implementation and enforcement of such sanctions policy.
4. All Member States enforce EU sanctions through criminal law, but the precise scope of penalties (including fines and imprisonment) can therefore vary from one Member State to another.