On September 14, 2026, the EU Commission adopted a Delegated Regulation updating Annex I to Regulation (EU) 2021/821 (“EU Dual-Use Regulation”). Although the changes have not yet entered into force, the Delegated Regulation sets out the expected amendments to the EU Dual-Use Regulation. Background Annex I to the EU Dual-Use Regulation lists dual-use items that require an export authorization pursuant to Article 3(1) of the EU Dual-Use Regulation. The EU Commission periodically, usually at least…
On 23 July 2026, the European Council adopted its 21st package of Russia sanctions as well as additional measures targeting Belarus. The package concentrates on sectors with the greatest impact on Russia’s war economy, including energy, shipping, gold, financial services (including crypto), trade, and the Russian military-industrial complex. Key elements include a full-year suspension of the oil price cap adjustment, a new tool allowing transaction bans on named refineries that process Russian crude (listing one…
Since we published our blog post on the relaxation of the Syria sanctions over the weekend, there have been two more related developments this week: (1) US guidance on the Syria sanctions relaxed on Friday, May 23, and (2) the EU’s move to formally lift nearly all of its remaining sanctions on Syria. United States: Guidance on Syria Sanctions Relaxation On Wednesday, May 28, the Office of Foreign Assets Control (“OFAC”) in the US Treasury…
On January 10, 2025, in a multilateral sanctions action, the US, Canada, EU, and UK sanctioned various Venezuelan individuals linked to the Venezuelan government and prominent state-owned entities. US Sanctions The US Treasury Department’s Office of Foreign Assets Control (“OFAC”) designated eight Venezuelan individuals as Specially Designated Nationals pursuant to Executive Order 13692, including the president of the Specially Designated National state-owned petroleum company, Petroleos de Venezuela, S.A., (PdVSA), the Venezuelan Ministry of Transportation and…