Photo of Dimitris Athanasopoulos

On January 10, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a sweeping set of actions to further reduce Russian revenues from energy, including blocking two major Russian oil producers, Gazprom Neft and Surgutneftegas, and imposing sanctions on a very significant number of oil-carrying vessels, opaque traders of Russian oil located in jurisdictions like Hong Kong and the UAE, Russia-based oilfield service providers, and Russian energy officials.  The U.S. Department of State also took steps to block two active liquefied natural gas projects, a large Russian oil project, and third-country entities supporting Russia’s energy exports. Lastly, the United Kingdom also joined the U.S. in sanctioning Gazprom Neft and Surgutneftegas – which, coupled with the joint Memorandum of Understanding issued by OFAC and OFSI on January 13, is a testament to the increased cooperation between the U.S. and UK authorities. Although there are wind-downs in place for most of these entities, this round of designations is likely to cause major disruptions in the market. We summarize the new restrictions in turn below:Continue Reading U.S. and UK Intensify Sanctions Against Russia’s Oil Sector in one of the Largest Rounds of Designations Since the Outbreak of the War

Key takeaways

  • On 12 September 2024 the UK government laid before Parliament the Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 (the Regulations). They were accompanied by new statutory guidance –
  • On 24 June 2024, the EU agreed the long-awaited 14th package of sanctions against Russia. These latest measures introduce several new thematic restrictions and imposed asset freeze measures on an additional 116 individuals and entities including Sovcomflot and the Volga Dnepr Group.
    Continue Reading EU 14th Sanctions Package against Russia

    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