The US Department of the Treasury’s designation of the Mriya Resort & Spa on November 8, 2018 for operating in Crimea highlights the sanctions risk of luxury hotels in the region. Mriya Resort & Spa is ultimately owned by Sberbank, which is subject to sectoral sanctions.
Other Russian companies subject to sectoral sanctions own Crimea-based luxury resorts. For example, energy giant Gazprom wholly owns ETTs v Parkovom OOO, which operates under the brand name Crimea Breeze Residence, through two intermediate holding vehicles. The resort advertises Gazprom as one of its “partners.”