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…
Global Trade & Sanctions Law
Overview of the EU’s Ninth Sanctions Package and the UK’s Latest Restrictive Measures Against Russia
EU’s Ninth Package On Friday 16 December 2022 the EU issued its ninth package of sanctions against Russia. Under the new package: Asset freezes have been imposed against 174 new individuals and entities including National Media Group, Credit Bank of Moscow, Dalnevostochniy Bank, AVO TV-Novosti, the All-Russia State Television and…
Implementing the Russian Oil Price Cap – Most Recent U.S. Guidance
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…
Additional Guidance on Recent Advanced Computing and Semiconductor Manufacturing Controls For China
On November 2, 2022, Assistant Secretary of the U.S. Department of Commerce Thea Rozman Kendler answered questions on the Bureau of Industry and Security’s (BIS) October 13 interim final rule (“the Rule”) regarding restrictions on certain advanced computing integrated circuits and semiconducting manufacturing items exported to the People’s Republic of…
Biden Administration Emphasizes CFIUS Enforcement and Key National Security Risks
The U.S. Department of Treasury recently released Enforcement and Penalty Guidelines (Guidelines) that outline conduct violating the Committee on Foreign Investment in the United States (CFIUS or Committee) regulations. Specifically, these Guidelines, the first of their kind, outline CFIUS’ process and practical considerations when deciding whether to impose penalties and how…
Preparing for the Oil Price Cap: What We Know So Far
Various reports indicate that the Group of Seven nations (G7) will announce its initial capped price for Russian-origin crude oil transported by maritime means (“seaborne”) this week. The cap will come into effect on December 5, 2022, for crude oil (including condensate) and February 5, 2023, for petroleum products. U.S.…
Latest UK and EU sanctions against Russia
The EU has published its eighth package of measures and the UK has published a number of new regulations to implement previously announced measures. Split across four regulations, the EU’s eighth package: Introduces new export controls relating to Russia. In addition to existing export bans, it is now prohibited to…
Commerce Issues Guidance on Recent Advanced Computing and Semiconductor Manufacturing Controls for China
On October 28, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued guidance on its October 7, 2022 interim final rule (Rule) that imposed new export controls on certain advanced computing integrated circuits (ICs), computer commodities that contain such ICs, and semiconductor manufacturing items exported to…
U.S. Government Further Targets Nicaragua’s Mining and Gold Sector, and Issues Expanded Executive Order with Broad Trade and Investment Sanctions Authorities
On October 24, 2022, the U.S. Department of Treasury Office of Foreign Assets Control (OFAC) and Department of State (State) announced new sanctions designations for Nicaragua, targeting a key state mining company and amending Executive Order (E.O.) 13851 to expand the U.S. government’s authority to issue sanctions in reactions to…
U.S. Commerce Department Imposes Sweeping China-Related Export Controls on Advanced Computing and Semiconductor Manufacturing Items
On October 7, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued an interim final rule (the “Rule”) imposing sweeping new export controls targeting certain advanced computing integrated circuits (ICs), computer commodities that contain such ICs, and certain semiconductor manufacturing items intended for the People’s Republic…