After many rumors of potential changes to the U.S. policy on Venezuela, on October 18, 2023 the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued four general licenses, representing a significant shift in its Venezuela sanctions program. Most pertinent for the shipping industry, certain sanctions that were in place against Petróleos
The recent English Court of Appeal judgment on Mints & others v PJSC National Bank Trust & PJSC Bank Otkritie Financial Corporation  EWCA Civ 1132 (“Mints”) on 6 October 2023 discussed several fundamental issues pertaining to concepts under the Sanctions and Anti-Money Laundering Act 2018 (“SAMLA”) and the secondary sanctions regulations thereunder, in particular the Russia (Sanctions) (EU Exit) Regulations 2019 (the “Regulations”). …
Continue Reading UK Sanctions – What is “Control”?
As we are nearing the one-year anniversary of the Russian oil price cap, this is an important reminder to operators across the industry that enforcement will be coming.
Continue Reading A little less conversation, more action
On Saturday (September 30, 2023), new UK and EU trade sanctions tightening the restrictions on the import of Russian-origin iron and steel products will come into effect.
While certain measures are already in place in relation to a number of listed iron and steel products (Listed Iron and Steel Products) that are of Russian origin…
On 2 August 2023 evening, the EU Commission released new FAQs (here and here; word search “2 August 2023”). Of greatest interest are the two new FAQs in the “Oil Import” section, relating to STS activity relating to Russian oil and petroleum products, in EU territorial waters. We set out extracts of these two below.
Continue Reading EU FAQs – STS in EU Territorial Waters
After the United Kingdom imposed new restrictions on legal advisory services on 30 June 2023, it is becoming increasingly more complicated for organizations to gauge what kinds of legal advice they are able to provide with respect to Russia. As these restrictions apply to in house legal and compliance functions as well as law firms…
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
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