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Sunny Mann

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Introduction During September 2023, the US, UK, and EU, and Japan, updated their Common High Priority Items Lists (“the List(s)”), with seven new Harmonized System (“HS”) codes. These coordinated Lists are composed of items identified as critical to Russia’s war effort, weapons systems and military development. The Lists highlight to businesses that there is a particularly high risk these sanctioned items may be the target of sanctions circumvention and possible diversion to Russia. Companies can…

On 28 June 2023, the US Bureau of Industry and Security (“BIS”) announced that the “Five Eyes” countries (Australia, Canada, New Zealand, the United Kingdom and the United States) have agreed to formally coordinate on export control enforcement, with a particular emphasis on the export controls targeting Russia and Belarus, which have been a core tool in the broader sanctions toolbox. Baker McKenzie has deep export controls expertise in four of the Five Eyes countries: …

On 29 June 2023, the UK introduced further restrictions to The Russia (Sanctions) (EU Exit) Regulations 2019 (“UK Russia Regulations”) through the Russia (Sanctions) (EU Exit) (Amendment) (No. 3) Regulations 2023 (the “Amending Regulation”). The principal change enacted by the Amending Regulation is the introduction of restrictions on the provision of certain legal advisory services, which entered into force on 30 June 2023. The Amending Regulation prohibits the direct or indirect provision of legal advisory…

On 9 May 2023, the President of the European Commission, Ursula von der Leyen, announced further details on the proposed eleventh package of EU sanctions against Russia. According to the press statement issued by the European Commission and related press reports, the proposed package mainly focuses on combatting circumvention of EU sanctions. More specifically, it would include the following additional measures: Ban of ‘shadow’ entities from Russia and third countries that are intentionally circumventing EU…