On November 14, 2025, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) amended two general licenses and issued two new general licenses (“GLs”)authorizing limited transactions involving Open Joint Stock Company Rosneft Oil Company (“Rosneft”) and Public Joint-Stock Company Oil Company Lukoil (“Lukoil”) and entities in which they respectively own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest (collectively “Rosneft and Lukoil Entities”). Rosneft and Lukoil…
The EU and UK have recently updated their respective lists of items subject to dual-use export controls, introducing important changes covering emerging technologies. In this blog post, we summarise the key updates under both the EU and UK regimes, and we highlight key steps that exporters can take in response to the changes. EU updates to the EU Dual-Use Regulation On 14 November 2025, the EU published Delegated Regulation (EU) 2025/2003, amending Annex I of…
In significant parallel actions this week, the EU and US imposed new sanctions on Russia. While the EU’s 19th sanctions package is much broader in scope, the measures overlap in their focus on the Russian energy sector, with the US imposing full blocking sanctions on Russia’s two largest oil majors, OJSC Rosneft Oil Company (“Rosneft”) and Lukoil OAO (“Lukoil”) and the EU imposing a full ban on Russia-origin liquified natural gas (“LNG”), among other energy sector…
On 10 October 2025, the Italian Government submitted to Parliament the draft legislative decree implementing Directive (EU) 2024/1226 on the definition of criminal offences and penalties for the violation of Union restrictive measures, which mandates the criminalisation of violations of EU restrictive measures. This long-awaited step marks a turning point in Italy’s approach to sanctions enforcement, aligning its legal framework with the EU’s Common Foreign and Security Policy (CFSP). Sanctions Violations Enter the Criminal Code…