As part of the EU’s 12th package of sanctions against Russia, adopted on 19 December 2023 (see our previous blog post here), the EU introduced a requirement under Article 12g of Regulation 833/2014 which requires EU exporters to include wording in certain goods contracts prohibiting the re-export of the goods to Russia and providing for “adequate remedies” in the event of a breach, in order to combat the circumvention of EU export bans and more…
On 14 December 2023, the Office of Financial Sanctions Implementation (“OFSI”) published its 2022-2023 annual review (see here). The review summarises OFSI’s activities over the 2022-2023 financial year and looks ahead at trends and OFSI’s priorities for the next year. Russia Sanctions The report has a particular focus on the UK’s expanded Russia sanctions regime, stating that by 31 March 2023, “130 oligarchs and family members” who had a combined net worth of around £145…
On 12 October 2023, the Price Cap Coalition (Australia, Canada, the European Union, France, Germany, Italy, Japan, the United Kingdom, and the United States) renewed efforts to ensure effective enforcement of the price cap on Russian-origin oil and petroleum products. Below we summarize the Price Cap Coalition’s joint advisory for the maritime oil industry and other actions taken by the United States. Maritime Oil Industry Advisory The Price Cap Coalition issued an advisory providing seven…
The UK has introduced a sanctions regime designed to target criminal actors, gangs and their financiers whose actions are causing instability in Haiti, pursuant to The Haiti (Sanctions) Regulations 2022, which enter into force on 28 December 2022. The restrictive measures consist of: financial sanctions measures through a targeted asset freeze on designated persons and prohibitions on making funds or economic resources available; trade sanctions, including restrictions on the trade in military goods and military…