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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 13 September 2023, European Commission President Ursula von der Leyen announced in her annual State of the Union Address that the European Commission (Commission) will launch an anti-subsidy investigation into Chinese subsidies to electric vehicle (EV) makers in China under EU trade rules. The Commission’s concern is that “global markets are now flooded with

During her annual State of the European Union speech on 13 September 2023, the President of the European Commission, Ursula von der Leyen, announced that “the Commission is launching an anti-subsidy investigation into electric vehicles coming from China.” An anti-subsidy measure (i.e., countervailing duties) is one of the trade defence instruments that a World Trade

Since February 2022, following the outbreak of the war against Ukraine, the EU adopted its 11th round of sanctions against Russia on 23 June 2023.

The latest sanctions package centres around a newly introduced anti-circumvention tool, described by the European Commission as a measure of last resort that “will allow the EU to restrict

On 23 June 2023, the EU published its 11th sanctions package.

We set out below a summary of key highlights in this latest update. These are all subject to further interpretative guidance provided by the EU, where applicable.

Designations / Asset Freeze Restrictions

The new round of sanctions extends the categories of persons that may be subject to an asset freeze, to include not only natural or legal persons, entities or bodies facilitating infringements of the prohibition against circumvention but also those that are significantly frustrating the provisions laid out by EU sanctions.

Over 100 additional individuals and entities have been added to the list of entities and individuals subject to asset freezing measures, including senior military officials, decision makers, Russian IT companies, banks, businesspersons, judges etc. In total 1572 entities and 244 individuals are currently listed as being subject to asset freezes.

Two new banks are designated, MRB Bank and CMRBank. An authorisation may be granted to release frozen funds or resources belonging to them if such funds or economic resources are necessary for the purchase, import or transport of agricultural and food products, including wheat and fertilizers.Continue Reading EU 11th Sanctions Package – Update

In May 2023, the European Union (EU) adopted Regulation (EU) 2023/1115 on the making available on the Union market and the export from the Union of certain commodities and products associated with deforestation and forest degradation (the Regulation). The Regulation was officially published on 9 June 2023 and will enter into force on 29

On 17 May 2023, the European Commission published its proposals to reform and modernise the Union Customs Code. These proposals follow years of discussions and calls for a structural change to the Union Customs Code, which was no longer adequate to meet new challenges and contained weaknesses that led to the emergence of obstacles to

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

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