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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 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

    Back to a new normal?

    As of 30 June 2024, the EU’s Temporary Crisis and Transition Framework for state aid measures, which was introduced following the Russian invasion of Ukraine, has expired in relation to state aid measures applicable to most sectors. Measures relating to the primary agriculture, fishery, and aquaculture sectors remain covered by

    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

    International efforts to seize assets of sanctioned Russian oligarchs and dispose of them in a timely fashion continue to face obstacles. Among these assets are the TANGO and AMADEA, two superyachts that were seized in the spring of 2022. More than a year and a half later, the TANGO and AMADEA are stuck in legal limbo. Taxpayers fund the staggering cost of upkeep, which (for full upkeep) can per annum be ten percent of a yacht’s total value. The costs include wages for a skeleton crew, insurance, docking fees, diesel supply and general maintenance.  Licenses from multiple jurisdictions are often needed to process transactions relating to a frozen asset, making payment for these services even more complicated and time consuming. Continue Reading Superyacht seizures and financing risk associated with sanctions

    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 de Venezuela, S.A. (PdVSA) and the Venezuela oil, gas and mining sectors have now largely been relaxed.Continue Reading Shipping briefing: Drill, baby, drill? A new Venezuelan wave for the shipping industry