sanctions

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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.

Continue Reading Carrot over the Stick? Reforms to OFSI Civil Enforcement Processes incentivise early engagement and settlement

The European Commission has granted six countries – Algeria, Nigeria, Norway, Qatar, the United Kingdom and the United States – an exemption from prior authorisation requirements for natural gas imports under the RePowerEU Regulation.

What does this mean?

Gas sourced from these six countries will no longer require prior authorisation under Article 5(3) or evidence…

I was recently quoted in TradeWinds on the growing number of tankers going dark as the EU considers expanding restrictions on maritime services connected to Russia’s oil trade.

https://www.tradewindsnews.com/tankers/dozens-more-tankers-going-dark-as-eu-eyes-russian-maritime-services-ban/2-1-1941406

It now looks increasingly certain that the EU, and likely the UK, will move to a comprehensive maritime services ban on the carriage of Russian crude…

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

Following the EU’s existing embargo on Russian crude oil and petroleum products, the European Commission has proposed, and the Council has now agreed in principle, a complementary Regulation designed to end the remaining inflows of Russian natural gas into the Union. The measure gives legal effect to the Commission’s May 2025 Roadmap towards ending Russian…

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.

Continue Reading New requirements for importing CN code 2710 cargo into the EU from 21 January 2026

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 others 

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 speculation

On May 23, the Office of Foreign Assets Control (OFAC) issued Syria General License 25, which authorizes a significant portion of previously prohibited transactions. The general license does not, however, amend or modify any of the existing Syria-related export controls under the International Traffic in Arms Regulations or Export Administration Regulations.

What does the…

On January 10, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a sweeping set of actions to further reduce Russian revenues from energy, including blocking two major Russian oil producers, Gazprom Neft and Surgutneftegas, and imposing sanctions on a very significant number of oil-carrying vessels, opaque traders of Russian oil located in jurisdictions like Hong Kong and the UAE, Russia-based oilfield service providers, and Russian energy officials.  The U.S. Department of State also took steps to block two active liquefied natural gas projects, a large Russian oil project, and third-country entities supporting Russia’s energy exports. Lastly, the United Kingdom also joined the U.S. in sanctioning Gazprom Neft and Surgutneftegas – which, coupled with the joint Memorandum of Understanding issued by OFAC and OFSI on January 13, is a testament to the increased cooperation between the U.S. and UK authorities. Although there are wind-downs in place for most of these entities, this round of designations is likely to cause major disruptions in the market. We summarize the new restrictions in turn below:Continue Reading U.S. and UK Intensify Sanctions Against Russia’s Oil Sector in one of the Largest Rounds of Designations Since the Outbreak of the War