The U.S. Department of the Treasury Office of Foreign Assets Control (“OFAC”) issued Russia-related General License 134 (“GL 134”) yesterday, which temporarily authorizes the delivery and sale of Russian-origin crude oil and petroleum products that are already on the water as of March 12, 2026. It is understood the policy intent
Carrot over the Stick? Reforms to OFSI Civil Enforcement Processes incentivise early engagement and settlement
Key Takeaways
- OFSI has published updated enforcement guidance introducing a new case assessment matrix, discount structures, a settlement scheme, and fixed penalties for procedural breaches.
- The new framework allows for cumulative discounts for voluntary disclosure (up to 30%), settlement (20%), and the Early Account Scheme (up to 20%), which can reduce penalties by up to 70%.
- Fixed penalties of £5,000 or £10,000 will apply to information, reporting, and licensing breaches.
- OFSI plans to double maximum penalties to £2 million/100% of breach value.
EU LNG and Pipeline Gas Import Ban – Timing under EU Sanctions (Article 3ra) vs RePowerEU
As a follow-up to our previous client alerts on the EU’s Russian gas phase-out (available here), we have prepared an infographic summarising how the EU sanctions framework (Regulation 833/2014) interacts with the RePowerEU phase-out Regulation (Regulation 2026/261), including the key contract cut-off and phase-out dates for both LNG and pipeline
How sanctions transformed the shipping industry in 2025
Key takeaways:
- EU and UK sanctions now increasingly target the full maritime logistics chain, including third country actors
- Shadow-fleet measures have intensified scrutiny on vessels and operators
- Compliance has become central to commercial decision-making
New requirements for importing CN code 2710 cargo into the EU from 21 January 2026
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.
UK Sanctions – Rosneft, Lukoil and others
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 othersChina introduces Special Port Service Fee on U.S.‑linked vessels
China’s Ministry of Transport will impose a new “Special Port Service Fee” on U.S. linked vessels from 14 October 2025, aligning with U.S. Section 301 measures taking effect the same day. In its announcement, the Chinese Ministry of Transport criticises the U.S. actions announced in April this year and warns of significant disruption to maritime
Refusing voyage orders: Sanctions risk assessments must be based on evidence, not speculation
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 speculationEU-nough Russian Oil – EU’s 18th Sanctions Package
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 PackagePotential U.S. tariffs on copper imports and the ‘short squeeze’: Legal considerations for physical sale and purchase contracts
- On July 8, 2025, President Trump indicated that the United States would impose 50% tariffs on copper imports. The tariffs are expected to be imposed by end of July or start of August.
- In response to the threat of tariffs, the global copper market has experienced significant change, as traders and end users