𝐴𝑙𝑙 𝑝𝑒𝑟𝑠𝑜𝑛𝑠, 𝑖𝑛𝑐𝑙𝑢𝑑𝑖𝑛𝑔 𝑛𝑜𝑛-𝑈.𝑆. 𝑝𝑒𝑟𝑠𝑜𝑛𝑠, 𝑒𝑛𝑔𝑎𝑔𝑒𝑑 𝑖𝑛 𝑖𝑛𝑡𝑒𝑟𝑛𝑎𝑡𝑖𝑜𝑛𝑎𝑙 𝑡𝑟𝑎𝑑𝑒 𝑎𝑛𝑑 𝑐𝑜𝑚𝑚𝑒𝑟𝑐𝑒 𝑠ℎ𝑜𝑢𝑙𝑑 𝑏𝑒 𝑎𝑤𝑎𝑟𝑒 𝑜𝑓 𝑠𝑎𝑛𝑐𝑡𝑖𝑜𝑛𝑠 𝑝𝑟𝑜ℎ𝑖𝑏𝑖𝑡𝑖𝑜𝑛𝑠 𝑎𝑝𝑝𝑙𝑖𝑐𝑎𝑏𝑙𝑒 𝑡𝑜 𝑛𝑜𝑛 𝑈.𝑆. 𝑝𝑒𝑟𝑠𝑜𝑛𝑠 𝑤ℎ𝑜 𝑖𝑛𝑣𝑜𝑙𝑣𝑒 𝑈.𝑆. 𝑝𝑒𝑟𝑠𝑜𝑛𝑠 𝑖𝑛 𝑠𝑢𝑐ℎ 𝑡𝑟𝑎𝑛𝑠𝑎𝑐𝑡𝑖𝑜𝑛𝑠.
What are the four primary prohibitions for the Crimea region?
- New investment in the Crimea region of Ukraine by a US person, wherever located
- Importation into the US, directly or indirectly, of any goods, services, or technology from the Crimea region of Ukraine
- Exportation, re-exportation, sale, or supply, directly or indirectly, from the US, or by a US person, wherever located, of any goods, services, or technology to Crimea
- Approval, financing, facilitation, or guarantee by a US person, wherever located, of a transaction by a foreign person where the transaction by that foreign person would be prohibited by this section if performed by a US person or within the United States.
Can a non-US financial institution process a US Dollar payment for shipping services in Crimea?
No. This involves the non-US FI to a service rendered in Crimea and involves indirectly a US correspondent bank in the transaction.
Can a non-US financial institution open a US Dollar account for a person in Crimea?
No. Opening an account for a person in Crimea in US Dollars, exposes the financial institution to US sanctions!
Can a non-US company maintaining a US Dollar account in Crimea move funds to another US Dollar account in Europe under the same beneficial owner?
A non-US company maintains a US Dollar business account with a bank located in Crimea to handle local transactions. In this situation, when moving funds, the non-US company is in receipt (or importing) a Crimea-origin financial service from the Crimean bank. The very act of maintaining a US Dollar account is prohibited as an importation of a Crimea-origin service.
Can a non-US person re-export US goods or goods incorporating partially US technology in Crimea?
No. The prohibition makes clear that both the direct and indirect exportation, re-exportation, sale, and supply of United States origin goods, services, or technology is also prohibited. Although not directly, the non-US person is exposed to the US sanctions.
Can non-US Visa or MasterCard provide payment services in US Dollars to merchants in Crimea?
No. Visa and MasterCard can no longer provide payment services in US Dollars to merchants in Crimea.
Can non-US person pay a commission to a US person for a Crimea customer referral?
No. This is a facilitation case. A US person cannot earn a commission for referring a Crimean customer to a foreign exporter. This is considered as an indirect interaction with the United States.
Can non-US person pay an invoice in US Dollars for services rendered in a port in Crimea?
No. Using the US financial system for paying services rendered in Crimea, exposes the FI to the US sanctions.