On October 9, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) added the entire International Criminal Court (“ICC”) to the Specially Designated Nationals and Blocked Persons List (“SDN List”) pursuant to Executive Order 14203 (“EO 14203”) and issued four general licenses authorizing specified transactions involving the court. Designation of the ICC Under EO 14203 OFAC has designated the ICC under section 1(a)(ii)(A) of EO 14203. The ICC designation follows OFAC’s…
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))…