On September 23, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) released for public inspection a Notice of Proposed Rulemaking that seeks to prohibit the sale or import of connected vehicles (CVs) with certain hardware and software that have a sufficient nexus to the People’s Republic of…
On September 12, 2024, the UK government published the Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 (the “Regulations”), granting the UK’s trade sanctions enforcement body, the Office of Trade Sanctions Implementation (OTSI), new implementation and enforcement powers effective from 10 October 2024. The Regulations also grant the Department…
On 24 June 2024, the EU adopted its 14th package of sanctions against Russia. The latest measures include: The designation of 116 additional individuals and entities across a number of industries for their responsibility in undermining Ukraine’s territorial integrity, sovereignty, and independence. A limited ban on contracts with Russian state…
Takeaways Sanctions operate prospectively and do not affect payment obligations to a non-sanctioned party accruing before sanctions became effective. Payment obligations under standby letters of credit at issue were autonomous and unconnected with the underlying transaction. The fulfilment of an independent obligation owed by a German bank to Irish-incorporated aircraft…
On February 24, 2023, the one-year anniversary of the Russia-Ukraine conflict, the United States released extensive new measures designed to impose additional sanctions on Russia for its aggression against Ukraine. These new measures are summarized below. The latest measures include actions by: The U.S. Treasury Department’s Office of Foreign Assets…
On February 24 and 25, 2023, the United Kingdom and European Union each adopted additional sanctions against Russia due to the ongoing conflict in Ukraine. These new measures are summarized below. EU Sanctions On 25 February 2023 the EU issued its tenth package of sanctions against Russia. Under this new…
This post marks the third entry in our Year-in-Review series. For prior posts, click here. Many of the first measures that the United States, European Union and United Kingdom collectively took against Russia in 2022 related to aircraft and international air travel. As the conflict broke out, each jurisdiction quickly…
This post marks the second entry in our Year-in-Review series. For prior posts, click here. Few sectors have been more affected by the sanctions on Russia than the energy industry. As Russia’s largest industry, it has been a focus of sanctions designed to deter the continuation and escalation of the…
On February 24, 2022, Russia’s entry into Ukraine set off an unprecedented wave of sanctions and export controls by a wide coalition of countries, including the United States, the United Kingdom, the European Union, Canada, Japan, South Korea, Australia, and New Zealand. The goal of these measures is to cripple…
On December 5, 2022, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) announced a $60 per barrel price cap on maritime transfers of Russian-origin crude oil. The final cap level is being implemented multilaterally by the Price Cap Coalition, which include the Group of 7 (G7) nations…