Ukraine Freedom Support Act 2014

On 18 December 2014, President Obama signed into law the Ukraine Freedom Support Act 2014, hardening the US Government’s position towards Russian insurgency in Ukraine.

In essence, the Act authorises, but does not compel, the President to impose sanctions in a variety of circumstances, including:

1. On Rosoboronexport, a Russian state agency involved in military procurement, and other Russian state-controlled firms which sell or transfer military equipment to Syria, or to entities in Ukraine, Georgia or Moldova without the consent of the governments in those nations. Persons (individuals or entities) that knowingly sponsor or provide financial, material, or technological support for, or goods or services to or in support of, such an entity may also be subject to sanctions.
2. To penalise Gazprom if it is found to be withholding significant natural gas supplies from Nato states, or Ukraine, Georgia or Moldova.
3. It further authorises the President to impose sanctions against persons that knowingly make a significant investment in certain types of Russian crude oil projects and to impose additional licensing requirements or other restrictions on the export of items for Russia's energy.
4. On Gazprom if it is determined to be withholding significant natural gas supplies from North Atlantic Treaty Organization (NATO) member countries, or further withholds significant natural gas supplies from countries such as Ukraine, Georgia, or Moldova.
5. On the opening, and a prohibition or the imposition of strict conditions on the maintaining, in the United States of a correspondent account or a payable-through account by a foreign financial institution that knowingly:
   1. engages in significant transactions involving sanctioned persons; or
   2. with respect to the Ukrainian crisis, facilitates a significant financial transaction on behalf of any Russian person included on the list of specially designated nationals and blocked persons maintained by the Department of the Treasury's Office of Foreign Assets Control. Such sanctions could have the effect of disabling the foreign financial institution from being able to process US dollar transactions.

The Managers will monitor and report on the implementation of the provisions of the Act.