GA Trade Nov-Dec interactive - page 29

been longtime supporters of
Putin and have helped him achieve
his policy goals. While the sanc-
tions are significant, the U.S. has
tried to minimize collateral costs
and have taken great care not to
have an adverse impact on global
energy prices.
The second type of sanctions is
sector-specific. In this vein, the
U.S. has further restricted Russian
access to capital markets for loans
maturing inmore than 30 days
with a particular eye to the finance
and energy sectors. In the defense
export sector, the U.S. has also
increased the number of items on
the list of prohibited dual-use
goods. Rather than focusing on
Russia’s current energy market,
these sanctions are specifically
aimed at limiting Russia’s ability to
develop technologies used in
fracking and arctic drilling, which
would enable them to secure future
energy supply.
The U.S. government maintains
that the current sanctions are
having the desired impact on the
Russian economy and see it as a
good sign that the Russian govern-
ment did not immediately impose
retaliatory measures following the
latest round of sanctions in
September. Officials recently
highlighted that the U.S. govern-
ment has made every effort to
cooperate with third countries
throughout the process. While
many third countries not directly
involved in the sanctions have been
very cooperative, the U.S. has made
it clear that they will be keeping a
close eye on the market, and
attempts to backfill and thereby
undermine the sanctions regime
will not be tolerated. The U.S. is
hopeful that sanctions will bring
about a peaceful resolution to the
Ukraine conflict; however, the U.S.
will only respond to concrete
action on the part of Russia and is
prepared to expand the sanctions
regime if necessary.
The sanctions, while aimed at
being straightforward, can be
complicated. While due diligence
on listed persons and company
ownership is often a clear first
step, one usually has to drill down
several layers to understand all the
implications of the sanctions for
companies with broader holdings.
More specific information regarding
the latest U.S. sanctions against
Russia is available at the U.S. Depart-
ment of the Treasury’s Ukraine-relat-
ed Sanctions resource center and the
U.S. Department of State’s Ukraine
and Russia Sanctions page.
Thepanel featured (from left to right):
PeterHarrell, DeputyAssistantSecretary for EconomicandBusinessAffairsat the
Departmentof State; AmbassadorDaniel Fried, Coordinator of SanctionsPolicyat theU.S.
Departmentof State; BrianO’Toole, Senior SanctionsPolicyAdvisor at theDepartment
of theTreasury; andMichael E. Burke, Partner atArnall, Golden,&GregoryLLP.
GermanAmerican TradeNov/Dec 2014
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