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
New requirements for importing CN code 2710 cargo into the EU from 21 January 2026
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
UK Sanctions – Rosneft, Lukoil and others
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
Refusing voyage orders: Sanctions risk assessments must be based on evidence, not speculation
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
U.S. eases Syrian sanctions; export controls remain unchanged
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
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
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
Gone with the Assad
The sudden collapse of the Assad regime in Syria has led to a rapidly evolving sanctions landscape. Notably, on January 6, 2025, the United States relaxed sanctions on certain transactions with Syria when the Office of Foreign Assets Control (OFAC) issued Syria General License 24 (GL 24), “Authorizing Transactions with Governing
Trump 2.0: Tariffs and China to take center stage
On November 5, 2024, the United States elected former President Donald Trump to become its 47th president. Following Trump’s re-election, and with Republicans gaining control Congress, U.S. trade policy is expected to undergo several significant changes based on Trump’s previous administration and his campaign promises.
In a recent blog post, our trade team outlines
BIS seeks comments on a proposed rule prohibiting transactions involving Chinese and Russian vehicle connectivity system hardware and software
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
UK government launches new agency to strengthen trade sanctions enforcement
- In October 2024 the UK government will launch the Office of Trade Sanctions Implementation (OTSI) to bolster the enforcement of UK trade sanctions.
- On 12 September 2024 the UK government laid before Parliament the Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 (the Regulations). They were accompanied by new statutory guidance –