On 28 August 2025, France, Germany, and the United Kingdom (the “E3”) formally triggered the “snapback” mechanism under the Joint Comprehensive Plan of Action (“JCPOA”), citing Iran’s continued non-compliance with its nuclear-related commitments. This move has been followed by weeks of unsuccessful negotiations at the United Nations aimed at extending the JCPOA framework. As a result of the snapback, and the failure to reach an agreement, all UN sanctions previously lifted under the JCPOA have…
On 30 September 2024, the UK Government issued a notice stating that from 31 October 2024, the provision of intra-group services will no longer be a specific licensing ground available in relation to professional and business services provided by UK companies to their Russian subsidiaries. Licence applications submitted before 31 October 2024 will not be affected by the change. Under Regulation 54C of The Russia (Sanctions) (EU Exit) Regulations 2019 (“UK Russia Regulations”), it is prohibited…
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 29 June 2024, the EU adopted a new Belarus sanctions package by amending Council Regulation (EU) 765/2006 (the “EU Belarus Sanctions“), effective from 1 July 2024. The amending regulation can be found here. The new package increases the alignment of the EU Belarus Sanctions with the EU’s sanctions against Russia (including those contained in Regulation (EU) 833/2014 (the “EU Russia Sanctions“), as recently updated), in order to address the risk of circumvention. The new…