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
EU Sanctions
EU FAQs – STS in EU Territorial Waters
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
New restrictions on legal advisory services – what do you need to know?
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…
EU introduces new anti-circumvention tool in latest sanctions package
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…
EU 11th Sanctions Package – Update
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
The EU is preparing an 11th round of sanctions: what we know so far
- Additional products added to the transit ban, including advanced
The European Commission sets central contact point on EU sanctions for foreign authorities and operators
To address the growing number of technical queries from non-EU operators and authorities on the scope and implementation of EU sanctions against Russia, the Commission has set up a new dedicated mailbox at ec-sanctions-international@ec.europa.eu
Non-EU operators and authorities who seek to receive guidance from the Commission on how to interpret EU sanctions are now invited…
CBAM will be implemented from 1 October 2023
The EU’s Carbon Border Adjustment Mechanism (CBAM) is a measure to ensure that goods importers pay a price for the resulting carbon emissions that is comparable to the price paid by EU domestic producers. During a transition period (starting 1 October 2023), EU importers will have to comply with reporting requirements.
In our alert on…
EU imposes ninth sanctions package on Russia in response to Ukraine conflict and annexation
The EU has introduced further economic and individual sanctions against Russia on Friday, December 16th, in response to the ongoing conflict in Ukraine and the annexation of Ukraine’s Donetsk, Luhansk, Zaporizhzhia, and Kherson regions. This is the ninth sanctions package since the conflict began in February 2022. The latest package extends the lists of restricted…
UK, EU and US Publish Guidance on Russian Oil Price Cap Restrictions
This client alert provides an update on the guidance published by the UK, EU and US on the relevant price cap for oil products of Russian origin, which apply from 5 February 2023. The alert explains the exceptions for non-Russian oil products, types of transactions and scenarios the price cap applies to, the “tier” list…