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Ryan McGrath

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As part of the EU’s 12th package of sanctions against Russia, adopted on 19 December 2023 (see our previous blog post here), the EU introduced a requirement under Article 12g of Regulation 833/2014 which requires EU exporters to include wording in certain goods contracts prohibiting the re-export of the goods to Russia and providing for “adequate remedies” in the event of a breach, in order to combat the circumvention of EU export bans and more…

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…

On 14 December 2023, the UK Government introduced two regulations (The Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2023 and The Russia (Sanctions) (EU Exit) (Amendment) (No. 5) Regulations 2023) amending The Russia (Sanctions) (EU Exit) Regulations 2019 to impose further restrictions on goods, technology, and sources of funding that the UK Government considers could support Russia’s war against Ukraine. The majority of the amendments came into force on 15 December 2023; however a…

European authorities have reached political agreement on two new initiatives which come in the context of the ‘Freeze and Seize’ Task Force, set up by the Commission in March 2022, and which will contribute to the enforcement of EU sanctions. The measure include the harmonisation of criminal offences and penalties for the violation of EU sanctions, and a new Directive to bolster the EU’s powers of asset recovery and confiscation. Harmonisation of criminal offences for…