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…
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.…
In response to Russia/Ukraine conflict, and Belarus’ ensuing support for Russia, the United States and global allies have imposed sweeping sanctions and export control restrictions on both Russia and Belarus. These actions are discussed extensively in our prior publications. The sanctions and export controls restrictions especially target Russia and have…
In the final few days of September, the U.S. and global allies issued a number of sanctions and export controls against actors who have supported Russia’s referendums in Ukraine and related attempts to annex four Ukrainian territories. The referendums have been condemned by the Group of 7 (G7) nations, which…