- The US sanctions relating to Ukraine and Russia are primarily directed at US persons.
- Non-US persons are not directly required to comply with the sanctions, so long as the relevant transaction and parties involved do not have any US nexus.
- If US individuals or companies, or any person within the United States is involved in a transaction, or there is another sufficient nexus to the US, the US sanctions may be applicable even to non-US persons involved.
- In addition, certain prohibitions relating to the sanctioned companies are directly applicable to non-US persons as well as to US persons:
- On April 28 the US expanded a practice it started with the April 11 sanctions on a Crimean entity, Chernomorneftegaz, by placing 13 of the 17 sanctioned companies on the Entity List. This is a list of prohibited parties under US export controls, separate from the SDN list administered by the US Treasury.
- As a result, both US and non-US persons are directly prohibited, under US law, from certain transactions relating to these 13 companies involving any goods, equipment, software or technology of US origin.
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