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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 24 July 2023, the EU Commission published updated FAQs (here and here) relating to the port ban restrictions under Articles 3eb and 3ec of the EU’s 11th Sanctions Package (implemented on 23 June 2023). We published a brief summary on the 11th Sanctions Package which can be reviewed here.

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

Although 2021 has predominantly been referred to as the “year of Russia” in terms of sanctions, the collapse of nuclear talks (JCPOA) as well as the social repression in the country have also shifted the focus to Iran, to some degree.

While designating members of the Islamic Revolutionary Guards Forces (IRGF) as Specially Designated Nationals

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

Companies and individuals alike have struggled to keep on top of the increased sanctions risks emanating from the heightening of international tensions in recent years. Recently, two English law cases, Havila Kystruten AS and Others v. STLC Europe Twenty Three Leasing Ltd and Another [2022] EWHC 3166 (Comm) (referred to as the Havila case) and

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

An alert was issued by the U.S. Office of Foreign Assets Control (OFAC) on April 17 warning about the potential evasion of the Russian-origin oil price cap. The alert came after OFAC had received reports that oil exported from the Eastern Siberia Pacific (ESPO) pipeline or ports on Russia’s eastern coast was trading above the

G7 leaders have announced new economic commitments designed to hold Russia accountable for its war against Ukraine. We discuss these commitments and provide an overview of the latest sanctions imposed on Russia by the United States, European Union, and United Kingdom in our recent alert on reedsmith.com.

The Department of Justice (DOJ) and the Department of Commerce announced the creation of a joint Disruptive Technology Strike Force on February 16, 2023. The strike force will be co-led by the assistant attorney general for the DOJ’s National Security Division and the assistant secretary for export enforcement at the Bureau of Industry and Security.