As summarized in our recent blog post, in response to recent threat of tariffs over the Greenland issue, the EU considered possible responses, including tariffs and triggering of the so-called Anti‑Coercion Instrument (“ACI”). Although these threats appear to have subsided for now, given trade volatility, usage of the ACI remains a live possibility and we wanted to provide a brief overview on the ACI and what companies can do to prepare in the event the…
After publishing a draft implementing decree (Atto del Governo n. 317) (see our previous blog post here), Italy has now approved final legislation (Legislative Decree No. 211 of 30 December 2025) implementing Directive (EU) 2024/1226 which enter into force on 24 January 2026, significantly changing the criminal enforcement landscape in relation to EU sanctions violations. Legislative Decree No. 211/2025 increases criminal liability risks, particularly in respect of EU sanctions compliance, for companies (under Legislative Decree…
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…