In May 2025, the UK government published the Cross-Government Review of Sanctions Implementation and Enforcement policy paper (“Cross-Government Review”). Led by the Foreign, Commonwealth and Development Office (FCDO), and supported by key sanctions departments and agencies across the UK government, the Cross-Government Review identifies steps to improve and facilitate compliance…
On October 22, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced significant new sanctions for Russia’s energy sector, designating Rosneft Oil Company (Rosneft) and Lukoil OAO (Lukoil) under Executive Order (EO) 14024 as Specially Designated Nationals (SDNs), along with dozens of directly named subsidiaries.…
On August 6, 2025, President Trump published a new Executive Order imposing secondary tariffs on India in response to its continued importation of Russian-origin crude oil. This marks both an escalation in U.S. trade negotiations with India and the first major Russia-related enforcement action of his second term. It also…
On February 24, 2025, the EU adopted its 16th package of sanctions against Russia, Belarus and non-government-controlled areas of Ukraine, symbolically marking the third anniversary of the start of Russia’s invasion of Ukraine and constituting the largest set of updates that we have seen in the past two years. On…
On December 16, 2024, the EU issued its 15th package of sanctions against Russia, new designations under the Belarus sanctions regime, and the first designations under the hybrid threats sanctions regime adopted in October 2024. These updates are summarized below. 1. Asset Freeze Measures Russia (Regulation 269/2014) New designations: 54…
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…