Yee Pushes U.S. Energy Financing While Advising State Vendors Of Russia Sanction Obligations

March 5, 2022

By Terri Jo Neff |

Arizona State Treasurer Kimberly Yee wants to ensure all State vendors understand their obligations in light of economic sanctions put on the Russian Federation by the U.S. and E.U. following Russia’s military invasion of Ukraine.

On Tuesday, Yee issued a Notice of Compliance about her expectation that State contractors, vendors, and other third-parties pay attention to the situation involving  Russia and have all “necessary consents, approvals, and authorizations of all governmental authorities in connection with any transaction” dealing with the State.

“As you are aware, the State of Arizona and the Arizona State Treasurer’s Office (ASTO) are subject to U.S. laws, regulations, and orders applicable to its business activities and financial transactions, including those related to the international trade controls and economic sanctions,” Yee wrote. “As a vendor of the State of Arizona, you have separate and independent obligations under these same laws.”

Yee added that the State of Arizona has no investments in Russia, and while economic sanctions are subject to change, she expects all contractors and third parties “acting as intermediaries for the State of Arizona” to be knowledgeable about and remain in compliance with export and import laws, regulations, sanctions, embargoes, and policies.

That includes, but is not limited to, securing all clearances, export and import licenses, or exemptions therefrom, and making all required filings with appropriate governmental bodies, she noted.

“If you or your agents are unable to comply with the above foreign transaction requirements – including compliance with the United States trade sanctions related to Russia– in regard to your independent relationship with State of Arizona, you are required to notify the Arizona State Treasurer’s Office in writing immediately,” Yee wrote.

Yee also used the notice to suggest State contractors and vendors not be associated with financing any oil or other energy trades with Russia.

“Instead, we respectfully request you consider financing and investing in energy production in the United States, so we can be energy independent,” she wrote. “This is not only beneficial from a foreign policy perspective, but it is also a safer domestic investment.”

Yee’s suggestion, she noted, goes against the wishes of the Biden Administration but she pointed out there is no law against financing U.S. energy production.

“Doing so is a sound investment that does not carry the risk of foreign investment in that sector,” Yee wrote.

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