On Friday 5th May, the Commission adopted its proposal for an 11th sanctions package.

According to the President of the European Commission, Ursula von der Leyen, “the focus of this package is now on cracking down on circumvention.”

The Commission is proposing the following elements:

  • Additional products added to the transit ban, including advanced tech products and aircraft parts;
  • Introducing a new tool to combat sanctions circumvention: the listing of products with a high-risk of circumvention to Russia, and the listing of countries involved in circumvention, notably certain third countries which have seen an increase in highly unusual trade flows from the EU in recent months. These countries would no longer be able to receive the listed high-risk circumvention products;
  • Measures targeting ships and trucks, to block any ship from using EU ports and locks, if it is determined to be transporting goods whose import, purchase or transfer into the Union is prohibited;
  • End of the exemption granted to Germany and Poland for the supply of crude oil;
  • Additional asset freezing measures, including against Chinese companies. It has been reported that the companies involved in circumventing sanctions are 3HC Semiconductors and King-Pai Technology, based in mainland China; Sinno Electronics, Sigma Technology, Asia Pacific Links, Tordan Industry, and Alpha Trading Investments in Hong-Kong.

The EU Member States are currently discussing this new round of sanctions. All 27 Member States must give their assent for this to become law.

To address the growing number of technical queries from non-EU operators and authorities on the scope and implementation of EU sanctions against Russia, the Commission has set up a new dedicated mailbox at ec-sanctions-international@ec.europa.eu

Non-EU operators and authorities who seek to receive guidance from the Commission on how to interpret EU sanctions are now invited to reach out to the Commission directly using this dedicated mailbox.

“This central contact point is meant to give more clarity specifically to non-EU authorities and operators, and encourage them to reach out directly to the Commission when they face difficulties in interpreting EU sanctions. It is also meant to help ensure that the flow of agrifood products and fertilisers to their countries continues unimpeded.”

European Commission

Further information is provided by the European Commission here

On 21 April 2023, the UK implemented The Russia (Sanctions) (EU Exit) (Amendment) Regulations 2023 (“18th Amendment”) which amends The Russia (Sanctions) (EU Exit) Regulations 2019 (“UK Russia Regulations”). This follows from the UK Government’s announcement on 24 February 2023 to, amongst other things, expand the list of products subject to restrictions on import into the UK, supply and delivery to non-UK countries and export restrictions. The announcement can be found on Gov.uk.

This client alert sets out a brief summary of headline amendments.

Continue Reading UK Sanctions – 18th Amendment

The Civil Rights Division of the Department of Justice has issued guidance clarifying that when a position requires access to export-controlled information or items, that requirement is not a basis for making an employment decision based on citizenship, immigration status, or national origin.

In our recent alert on reedsmith.com, we examine U.S. export control requirements, immigration requirements, and share best practice.

The Bureau of Industry and Security (BIS) has clarified two enforcement policies in an attempt to incentivize voluntary self-disclosures and disclosures about others’ possible violations of the Export Administration Regulations (EAR).

In our recent post, we consider the implications of this latest development.

An alert was issued by the U.S. Office of Foreign Assets Control (OFAC) on April 17 warning about the potential evasion of the Russian-origin oil price cap. The alert came after OFAC had received reports that oil exported from the Eastern Siberia Pacific (ESPO) pipeline or ports on Russia’s eastern coast was trading above the price cap.

As per the current sanctions, U.S. persons are prohibited from offering certain services related to the maritime transportation of Russian oil, unless the oil was purchased at or below the predetermined price cap. Additional prohibited services include trading/commodities brokering, financing, shipping, insurance, flagging, and customs brokering.

We provide further analysis of the OFAC’s recommendations in this post.


The U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) recently reached a settlement with a multi-asset trading platform where, to settle its potential civil liability for violations of sanctions against Iran, Cuba, and Venezuela, the crypto platform agreed to pay $72,230.

In a recent post, our team outlines the alleged sanctions violations and breakdowns how compliance enforcement in the crypto industry has become a key focus for OFAC.

The UK government has opened an exploratory consultation to consider a range of possible policy measures to mitigate carbon leakage and to ensure the correct policy infrastructure is in place to decarbonize.

In a recent post, our team examines the potential measures, like a domestic carbon border adjustment mechanism (CBAM), that the UK government could introduce to mitigate carbon leakage risk. The team also explores what is required of the embodied emissions reporting system to ensure it efficiently supports the implementation of carbon leakage mitigation

The Court of International Trade continues to focus in on issues relating to Chinese-origin goods and on March 17 upheld the Section 301 tariffs on Chinese-origin goods identified on List 3 and List 4A. This decision comes despite the plaintiffs in In re Section 301 Cases arguing that the U.S. Trade Representative (USTR) violated the Administrative Procedure Act (APA) and seeking to vacate the tariffs.

This issue has long been debated and this case started two-and-a-half years ago when a group of importers challenged the USTR’s statutory authority to issue a subset of tariffs covering $300 billion of Chinese goods, known as List 3 and List 4A. Our team provides a short summary.

The U.S Department of Commerce recently released the first of three expected Notices of Funding Opportunities under the CHIPS and Science Act of 2022. This act aims to develop the domestic semiconductor supply chain, provide jobs, restore the country’s leadership in semiconductor manufacturing, and advance U.S. national and economic security. 

In our latest alert, found on reedsmith.com, our team examines how a primary focus when evaluating funding applications is how proposed projects will advance U.S. national and economic security.