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Ukraine Sanctions - June 2014 Update
On the 23rd June the EU passed regulation 692/2014 which prohibits imports into the EU of good originating from Crimea and prohibits the provision of financial assistance, as well as insurance and reinsurance related to the import of such goods. The regulation came into force on 25th June 2014 although the prohibitions do not apply until 26th September 2014 to the completion of contracts concluded before 25th June 2014 – but here, notice has to be given at least 10 working days in advance to the authorities.
There is also an exception for goods originating in Crimea which have a Ukrainian certificate of origin. Further guidance may be given in due course by HM Treasury. The regulation is directly applicable throughout the EU and also outside the EU to any person which is a national of a member state. For text of the regulation: http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:JOL_2014_183_R_0004&from=EN
The International Group is producing a circular on this topic which will be available shortly.