Between February 21 and February 23, 2022, in response to recent actions by the Russian Federation (“Russia”) that threaten the peace, stability, sovereignty and territorial integrity of Ukraine, U.S. President Joseph R. Biden Jr. (the “President”) ordered the implementation of a number of sanctions-related measures, as further described below. First, on February 21, 2022, the President issued Executive Order 14065, which, based on a finding that Russia’s purported recognition of the so-called Donetsk People’s Republic (“DNR”) and Luhansk People’s Republic (“LNR”) regions of Ukraine contradicts Russia’s commitments under the Minsk agreements (a series of international agreements entered into in 2014 and 2015 and intended to end hostilities in the Donbas region of Ukraine), establishes a comprehensive sanctions program targeting the DNR and LNR regions. Subsequently, on February 22 and February 23, 2022, the President imposed additional U.S. sanctions targeting Russian sovereign debt, prominent Russian state-owned financial institutions, several Russian elites and their family members who have close ties to the Kremlin and the Nord Stream 2 gas pipeline.
February 23, 2022
