The sanctions enforcement storm is underway. As we highlighted in the introduction to this blog series, the quickly evolving sanctions landscape of recent years has increased the complexity of compliance. Keeping up with ever-changing multi-jurisdictional sanctions and adapting compliance practices has proven challenging for companies with complex operations and supply chains. Instances of non-compliance can be inevitable. A company’s investigation triage plan should evaluate mandatory disclosure obligations and, if there are none, the availability and…
The U.S. has recently made public that a number of countries have joined a pledge to implement export controls on spyware technology. This is part of a broader initiative to establish trade barriers for cyber-related items that could potentially be used in human rights abuses. On March 18, Finland, Germany, Ireland, Japan, Poland, and South Korea became part of the commitment, joining the U.S., Australia, Canada, Costa Rica, Denmark, France, New Zealand, Norway, Sweden, Switzerland,…
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…
In brief After intense debates in the Council of the European Union, the EU has agreed on an 11th package of sanctions against Russia and its supporters in their aggression against Ukraine. The relevant Council Regulation (EU) 2023/1214 and Council Regulation (EU) 2023/1215 (respectively amending Regulation (EU) 833/2014 and Regulation (EU) 269/2014) have been published in the Official Journal of the EU, LI 159/1 on 23 June 2023. Following publication, the amending regulations entered into…