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Sylvain Guelton (UK)

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On 16 June 2026, the UK announced a new package of sanctions under its Russian sanctions regime. The package targets Russia’s shadow fleet, financial networks, military procurement channels, and broader support infrastructure. In total, 70 individuals and entities have been designated under the new package. The sections below summarise the key elements of the package. New sanctions targeting Russia’s shadow fleet and maritime evasion A central focus of the new measures is Russia’s “shadow fleet”,…

France has taken its first formal step toward implementing Directive (EU) 2024/1226, which requires all EU Member States to criminalise the violation and circumvention of EU restrictive measures. The Directive was adopted to address persistent divergences in national enforcement regimes and to ensure that breaches of EU sanctions are treated consistently as criminal offences across the European Union (EU). The Directive establishes a minimum harmonisation of offences and penalties, covering conduct such as providing funds…

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…

The French authorities (French Treasury – Direction Générale du Trésor) have provided an important update for operators in France regarding the renewal of licenses for the provision of intragroup services and software to Russia. Under Article 5n of Regulation (EU) 833/2014 (“EU Russia Sanctions Regulation”), the supply of certain services and software to persons established in Russia is prohibited. However, until 30 September 2024, the supply of these services and software to Russian entities owned…