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In recent years, the sanctions clause has become a “must have” contractual clause. Any company that engages in activity involving high-risk goods or services, or relating to or in connection with high-risk jurisdictions, should incorporate clear and robust sanctions clauses in its contracts. Businesses face complex issues when interpreting and drafting sanctions clauses, requiring an

On October 15, 2023, OFAC issued General License 44, which temporarily authorized transactions related to oil and gas sector operations, including transactions involving PdVSA.
Continue Reading OFAC issues wind-down license for Venezuelan oil

After various delays, on 19 February 2024 the EU Commission issued its FAQ guidance on Article 3q of Council Regulation (EU) No. 833/2014 (as amended). The FAQ document provides some key clarifications sought by the market. However, some uncertainties remain
Continue Reading EU Clarifies Article 3q for Tanker S&P Market

On 18 December, the EU announced their 12th round of sanctions targeting Russia. This comes against the backdrop of a flurry of Russia sanctions related activity and a number of designations of third country actors believed to be engaged in price-cap circumvention.
Continue Reading Christmas comes early for G7 operators – EU adopts 12th package of sanctions against Russia, changes to the Price Cap Model

On 9 June 2023, the UK implemented The Republic of Belarus (Sanctions) (EU Exit) (Amendment) Regulations 2023 which amends The Republic of Belarus (Sanctions) (EU Exit) Regulations 2019 (the “Belarus Regulations”). The latest approach allows the UK government to more strongly target exports from Belarus and to ramp up restrictions against Belarus to avoid any

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 UK, EU and U.S. have each published the relevant price cap for petroleum products falling under HS/CN Code 2710 that are of Russian origin or consigned or exported from Russia to non-G7 countries (Restricted Petroleum Products), and have also updated their guidance on the scope and practical implementation of the price cap restrictions. We

This client alert provides an update on the guidance published by the UK, EU and US on the relevant price cap for oil products of Russian origin, which apply from 5 February 2023. The alert explains the exceptions for non-Russian oil products, types of transactions and scenarios the price cap applies to, the “tier” list

The UK, EU and U.S. have each released information on the relevant price cap for oil products with HS/CN Code 2709 of Russian origin or exported from Russia shortly before the ban on maritime services for the transportation of Russian crude oil on December 5th, 2022. This announcement follows the publication of the UK’s “Maritime