As the situation in the Ukraine continues to spiral, FFLs are alerted to pay attention to the July 16, 2014 Department of Treasury imposition of sanctions against various businesses in the Russian Federation, including eight firms in the arms or related material sector.  The recent  announcement includes questions and answers that could immediately impact importers and dealers, including those with Kalashnikov products in inventory. This federal ban started on March 16, 2014 when the President issued Executive Order 13661, “Blocking Property of Additional persons Contributing to the Situation in Ukraine.”  Four months later, the Treasury Department issued its “Announcement of Treasury Sanctions” on Entities Within the Financial Services and Energy Sectors of Russia, Against Arms or Related Material Entities, and those Undermining Ukraine’s Sovereignty.” The Treasury Announcement includes a listing and description of eight companies operating within the Russian federation, and includes Almaz-Antey, Bazalt, JSC Concern Sozvezdie, JSC MIC NPO Mashinostroyenia, Kalasnikov Concern, KBP Instrument Design Bureau, Radio-Electronic Technologies, and Uralvagonzavod. On the Treasury website, at the bottom of a rolling question and answer section, are two questions and answers relative to handling of e.g., Kalashnikov products that may be in inventory, making a distinction between those fully owned compared to those for which moneys may still be outstanding to the foreign manufacturer.  Specifically, “If a U.S. person is in possession of a Kalashnikov Concern product that was bought and fully paid for prior to the date of designation (e.g., no payment remains due to Kalashnikov Concern), then that product is not blocked and OFAC sanctions would not prohibit the U.S. person from keeping or selling the product in the secondary market, so long as Kalashnikov Concern has no interest in the transaction.” The U.S. Treasury Department can be contacted at (202) 622-2000 and can be found on-line at Treasury.gov.