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Paul Amberg

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On 18 December 2023, the EU published its 12th package of sanctions targeting Russia. The changes implemented in this package have a material impact on all businesses with a continued or residual presence in Russia, including those seeking to exit and divest from Russia. Moreover, all companies, even those not trading directly with Russia, should be mindful of the increased focus on targeting circumvention.In our latest on-demand webinar, we provide you with an overview of some…

On January 16, 2024, the United States Department of Commerce’s Bureau of Industry and Security (“BIS”) announced further enhancements to its voluntary self-disclosure (“VSD”) policy under the Export Administration Regulations (15 C.F.R Parts 730–774, the “EAR”). These enhancements build upon previous VSD developments announced on June 30, 2022 and April 18, 2023, in order to increase the efficiency and effectiveness of the VSD process. Our blog posts on these previous VSD developments are available here…

On December 5, 2023 and December 6, 2023, respectively, the US and UK Governments announced new sanctions and export control measures targeting Russia focused on persons and entities in third countries supporting Russia’s military and defense industrial base and its war in Ukraine. US Sanctions and Export Control Updates The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced sanctions targeting a network led by Belgium-based individual, Hans De Geetere, as well…

On 18 December 2023, the EU published its 12th package of sanctions targeting Russia via Regulation (EU) 2023/2878 and Regulation (EU) 2023/2875, amending Regulation (EU) 833/2014 and Regulation (EU) 269/2014, respectively (collectively, “12th EU Russia Sanctions Package”). The amendments to Regulation (EU) 269/2014 (related to Designated Persons (“DPs”)) are effective immediately while the amendments to Regulation (EU) 833/2014 become effective today, 19 December 2023. These amendments have a material impact on all businesses with a…