The expiry of the EU State Aid Temporary Crisis and Transition Framework
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
EU 14th Sanctions Package against Russia
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.
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Navigating the key elements of sanctions clauses
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
OFAC issues wind-down license for Venezuelan oil
On October 15, 2023, OFAC issued General License 44, which temporarily authorized transactions related to oil and gas sector operations, including transactions involving PdVSA.
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EU Clarifies Article 3q for Tanker S&P Market
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
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Christmas comes early for G7 operators – EU adopts 12th package of sanctions against Russia, changes to the Price Cap Model
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.
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Shipping briefing: Drill, baby, drill? A new Venezuelan wave for the shipping industry
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
UK Sanctions – What is “Control”?
The recent English Court of Appeal judgment on Mints & others v PJSC National Bank Trust & PJSC Bank Otkritie Financial Corporation [2023] 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”).
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A little less conversation, more action
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