As summarized in our recent blog post, in response to recent threat of tariffs over the Greenland issue, the EU considered possible responses, including tariffs and triggering of the so-called Anti‑Coercion Instrument (“ACI”). Although these threats appear to have subsided for now, given trade volatility, usage of the ACI remains a live possibility and we wanted to provide a brief overview on the ACI and what companies can do to prepare in the event the…
On 21 January 2026, the EU’s restrictions on the import of refined petroleum products deriving from Russian-origin crude oil entered into force. The restrictions, introduced as part of the EU’s 18th package of sanctions targeting Russia under Article 3ma of EU Regulation 833/2014 (as previously summarised in our blog post here), prohibit the direct or indirect purchase, import or transfer into the EU of refined petroleum products obtained from third countries that derive from Russian-origin…
Background On 15 January 2026, the German Parliament adopted legislation transposing Directive (EU) 2024/1226, which defines and harmonizes criminal offenses and penalties for breaches of all EU restrictive measures (i.e., sanctions). The directive’s core provision, Article 3, sets out a comprehensive list of criminal offenses that cover most types of sanction violations. Transposing the directive into national law, Germany revised key provisions in sections 18 and 19 of the Foreign Trade and Payments Act (Außenwirtschaftsgesetz(AWG))…
In a significant move to counter Russia’s destabilizing actions abroad, the Council of the EU has enacted Regulation (EU) 2024/2642 on 8 October 2024 concerning restrictive measures in view of Russia’s hybrid, destabilizing activities (“EU Russia Destabilization Sanctions”). The new sanctions framework aims at targeting individuals and entities involved in hybrid activities that undermine the fundamental values and security of the EU, its member states, and international organizations. The decision, proposed by Josep Borrell, the High…