There have been a number of fluctuating developments in the UN and EU’s approach to Iran over the past few weeks, with a further attempt to salvage negotiations in an agreement on 10 September. We set out further details herein, including consideration of the sanctions implications. Political Developments At the end of August, amid concerns regarding Tehran’s continued resistance to international nuclear oversight and Russia’s upcoming presidency of the United Nations Security Council, the E3…
Background Article 8a of Council Regulation (EU) 833/2014 (the “EU Russia Regulations”) imposes obligations on EU parents to undertake “best efforts” to ensure that activities conducted by their non-EU subsidiaries do not undermine EU sanctions targeting Russia and Belarus. This requirement, which was introduced in June 2024, raises complex questions about the scope of EU sanctions and their applicability to the activities of non-EU entities. The Commission previously issued guidance in November 2024 in relation…
Introduction On 22 July 2025, the UK Office of Financial Sanctions Implementation (“OFSI”), which is responsible for the enforcement of financial sanctions in the UK, opened a public consultation on proposed amendments to its civil monetary penalty procedures. The consultation (available here) seeks input on five key categories of amendments to OFSI’s current civil enforcement processes as follows: Responding to the consultation The deadline to provide responses to the consultation is 23:59 London time on…
On 18 July 2025, the UK Government announced a lowering of the Oil Price Cap (“OPC”) to further inhibit Russia’s ability to use oil revenues to finance its illegal invasion of Ukraine. The OPC was first introduced in December 2022 to reduce Russia’s oil revenues in response to the invasion of Ukraine that same year. The OPC prevents G7 companies from shipping, insuring or servicing any Russian crude oil sold above the OPC price of…