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Ben Smith

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In recent weeks, there have been a number of noteworthy developments highlighting the increasing focus that US, EU, UK and other governments are placing on the potential circumvention of sanctions against Russia, and the roles of third countries and companies in facilitating the circumvention or undermining of such sanctions measures. These anti-circumvention efforts are taking place in the context of the G7’s concerted effort to bolster sanctions enforcement around the world, through the creation of…

The UK has announced a new package of sanctions against Russia. This will include the following sanctions: Export bans on every item Russia has been found using on the battlefield to date. Goods will include aircraft parts, radio equipment, and electronic components that can be used by the Russian military industrial complex, including in the production of UAVs. Import bans on 140 goods including iron and steel products processed in third countries. Extension of existing…

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…

The UK has adopted The Russia (Sanctions) (EU Exit) (Amendment) (No. 16) Regulations 2022 which introduce new restrictions against Russia and expand existing ones. The Legislation enters into force on 5 December 2022. The Russia (Sanctions) (EU Exit) (Amendment) (No. 16) Regulations 2022: Prohibit the direct or indirect supply or delivery by ships of certain oil and oil products falling within commodity codes 2709 and 2710, from a place in Russia to a third country, or from one…