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Key Takeaways

  • The measure seeks to close remaining ‘loopholes’ in the EU’s Russian oil embargo and maintain consistency with allied sanctions.
  • The safe-harbour country presumption eases compliance for imports from established crude exporters but can be rebutted by competent Member State authorities.
  • Risk-based due diligence remains essential: importers must be ready to demonstrate non-Russian origin if challenged.
  • Companies should now review supply chains, update contractual clauses, and ensure they can substantiate origin claims in due course.
  • On 15 October 2025, the UK announced intent to impose similar measures in due course.

Continue Reading New requirements for importing CN code 2710 cargo into the EU from 21 January 2026

In continuation of the UK’s sanctions restrictions against Russia, on 15 October 2025, the UK imposed further sanctions on various entities and vessels.

The headline designations include:

  • PJSC Rosneft Oil Company
  • Nayara Energy Limited (which was already subject to EU asset freeze restrictions)
  • Alghaf Marine DMCC
  • PJSC Lukoil

In some regards, these designations mirror the intent of the EU (noting their upcoming 19th sanctions package is intended to impose a full transaction ban on Russian oil majors), signaling joint efforts on the sanctions efforts against Russia between the UK and EU in recent months.Continue Reading UK Sanctions – Rosneft, Lukoil and others 

Tonzip Maritime Ltd v. 2Rivers Pte Ltd (formerly Coral Energy Pte Ltd) [2025] EWHC 2036 (Comm)

A. Key facts

On 5 November 2021, Tonzip Maritime Ltd (Owners), owner of the vessel CATALAN SEA (the Vessel), entered into a voyage charterparty with 2Rivers Pte Ltd (formerly Coral Energy Pte Ltd) (2Rivers) for the carriage of oil from Primorsk, Russia, to Aliaga, Turkey (the Charterparty).Continue Reading Refusing voyage orders: Sanctions risk assessments must be based on evidence, not speculation

On 18 July 2025, the EU announced the 18th sanctions package against Russia and Belarus. The legislative texts were published on 19 July 2025. As of this date, the latest restrictions indicate a misalignment between the EU / UK, and other G7 members, including the United States.Continue Reading EU-nough Russian Oil – EU’s 18th Sanctions Package

As anticipated, on June 30, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced the implementation of President Trump’s Executive Order, “Providing for the Revocation of Syria Sanctions.” This action adds to General License 25 and removes the broad U.S. sanctions previously in place against Syria and the former regime…

U.S. concerns surrounding the proliferation of the Chinese shipbuilding industry pre-date the current tariff wars.  Under the previous Biden administration, on March 12, 2024, various U.S. labor unions filed a petition requesting an investigation into the acts, policies, and practices of China targeting the maritime, logistics, and shipbuilding sectors for dominance.

Following a year-long investigation, including input from industry and a public consultation, the United States Trade Representative (“USTR”) determined that China’s targeting of the maritime, logistics, and shipbuilding sectors for dominance is unreasonable and burdens or restricts U.S. commerce and is therefore actionable under Sections 301(b) and 304(a) of the Trade Act.Continue Reading U.S. section 301 strikes back: Additional U.S. port service fees on vessels with China nexus; potential far-reaching implications for leaseback arrangements

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

The sudden collapse of the Assad regime in Syria has led to a rapidly evolving sanctions landscape. Notably, on January 6, 2025, the United States relaxed sanctions on certain transactions with Syria when the Office of Foreign Assets Control (OFAC) issued Syria General License 24 (GL 24), “Authorizing Transactions with Governing…

  • In October 2024 the UK government will launch the Office of Trade Sanctions Implementation (OTSI) to bolster the enforcement of UK trade sanctions.
  • 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 –
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On Tuesday 23rd July, energy and natural resources partners Sachin Kerur and James Willn, along with international trade partner Leigh Hansson, hosted the highly anticipated webinar “Sanction Strategies: Focus on India, China, and the Middle East.” During this insightful session, the team delved into the latest sanctions decisions, explored the implications for companies in these…