The Bureau of Industry and Security (BIS) is seeking comments on a proposed rule that would prohibit transactions involving Vehicle Connectivity System (VCS)[1] hardware and covered software designed, developed, manufactured, or supplied by persons owned by, controlled by, or subject to the jurisdiction of China (including Hong Kong) or Russia. Comments will be due
sanctions
UK government launches new agency to strengthen trade sanctions enforcement
Key takeaways
Webinar on Sanction Strategies: Insights on India, China and the Middle East
On Tuesday 23rd July, energy and natural resources partners Sachin Kerur and James Willn, along with international trade partner Leigh Hansson, hosted the highly anticipated webinar “Sanction Strategies: Focus on India, China, and the Middle East.” During this insightful session, the team delved into the latest sanctions decisions, explored the implications for companies in these…
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.
Continue Reading EU 14th Sanctions Package against Russia
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…
Superyacht seizures and financing risk associated with sanctions
International efforts to seize assets of sanctioned Russian oligarchs and dispose of them in a timely fashion continue to face obstacles. Among these assets are the TANGO and AMADEA, two superyachts that were seized in the spring of 2022. More than a year and a half later, the TANGO and AMADEA are stuck in legal limbo. Taxpayers fund the staggering cost of upkeep, which (for full upkeep) can per annum be ten percent of a yacht’s total value. The costs include wages for a skeleton crew, insurance, docking fees, diesel supply and general maintenance. Licenses from multiple jurisdictions are often needed to process transactions relating to a frozen asset, making payment for these services even more complicated and time consuming. Continue Reading Superyacht seizures and financing risk associated with sanctions
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
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
Further UK and EU sanctions on Russian iron and steel come into effect
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…
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