On 5 September 2024, the UK amended the scope of its Russia sanctions relating to the provision of certain legal advisory services to non-UK persons, as contained in Regulations 54D and 60DB of The Russia (Sanctions) (EU Exit) Regulations 2019 (“UK Russia Regulations”), via The Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2024 (the “Amending Regulation”). The Amending Regulation entered into force on 6 September 2024, in short (i) clarifying the knowledge a person must have…
On August 9, 2024, the US, EU, UK and Canada released a joint statement announcing new sanctions against Belarus, referring to the fourth anniversary of fraudulent presidential elections in Belarus that resulted in Alexander Lukashenko remaining in power. These authorities cited Belarus’s support for Russia’s war of aggression against Ukraine and ongoing human rights abuses in Belarus as the motivations for the latest round of sanctions. Members of our global sanctions team in the US,…
On 11 June 2024, the UK Court of Appeal handed down its judgment in the case of Celestial Aviation Services Limited v UniCredit Bank GmbH (London Branch) [2024] EWCA Civ 628. In summary, the Court of Appeal determined that, in the context of payment obligations under standby letters of credit (“LCs”), sanctions measures relating to financing the supply of restricted items can apply retrospectively as well as prospectively, significantly widening the scope of application of…
The Middle East is an increasingly important jurisdiction for Western governments from a Russia sanctions foreign policy perspective, as there is a perception that increased trade flows between the Middle East and Russia means that Western sanctions are effectively being circumvented. Companies in the Middle East may have concerns about triggering EU / UK / US sanctions jurisdiction, or being directly designated by Western governments for engaging in activities deemed to be contrary to the…