Ken Weckstein and Aidan Delgado co-authored the article, "Be Proactive In Complying With Ukraine-Related Sanctions," which was published by Law360. The article serves as a warning to anyone with business dealings in Eastern Europe to be aware of the restrictions of the Ukraine-related sanctions program.
From the Article
"The broad language of the EOs should be deeply worrisome to anyone with business ties to Eastern Europe. Among other things, the EOs makes it a violation 'to have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of' any sanctioned party or any entity 'owned or controlled by, or to have acted or purported to act for or on behalf of' a sanctioned party. Strictly read, this language could prohibit a vast range of seemingly-innocent transactions. Does a bank transferring payments for a sanctioned Russian official indirectly ast 'on behalf of' that official? Does a bank transferring payments for a sanctioned Russian official indirectly act 'on behalf of' that official? Does a subcontractor providing screws to a Russian defense company provide goods and services 'in support of' the sanctioned company?"