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

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”).
Continue Reading UK Sanctions – What is “Control”?

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

Since February 2022, following the outbreak of the war against Ukraine, the EU adopted its 11th round of sanctions against Russia on 23 June 2023.

The latest sanctions package centres around a newly introduced anti-circumvention tool, described by the European Commission as a measure of last resort that “will allow the EU to restrict

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

In coordination with the G7 and other international partners, the U.S. implemented new Russia-related sanctions and export controls on May 19, 2023. The U.S. also released an additional select list of potential export control evasion “red flags.”

Restrictive economic measures

The Office of Foreign Assets Control (OFAC):

  • Sanctioned 22 individuals and 104 entities in more