On 14 June 2023, the UK Office of Financial Sanctions Implementation (“OSFI”) published updated guidance for the Maritime Services Ban and Oil Price Cap (the “Updated Guidance”). The Updated Guidance can be found here and our previous blog posts on UK Maritime Services Ban and Oil Price Cap can be found here and here. The Updated Guidance provides additional clarity and detail on the following: OFSI has also issued General Licence INT/2023/3074680 and updated the…
This week in our Sanctions Enforcement Around the World series, we bring you the view from Belgium. Before Russia took the decision to recognise the non-government controlled areas of the Donetsk and Luhansk oblasts of Ukraine and to send troops into the region, a limited number of judicial proceedings related to violations of Union restrictive measures were reported. With the introduction of the first package of sanctions against Russia in February 2022, in view of…
On 9 June 2023, the EU Council published draft legislation introducing EU-wide criminal penalties and stricter enforcement for the evasion of EU sanctions. The EU Council’s press release explains that it has settled its position on the terms of new legislation to align criminal offences and penalties across the EU, before commencing negotiations with the European Parliament on its finalisation. Currently, Member States are not obligated to criminalise sanctions circumvention, however, once finalised, Member States…
This week in our Sanctions Enforcement Around the World series, we bring you the view from Spain. In Spain, fines for sanctions violations are not published but sanctions enforcement actions have been the subject of reports in the press. Generally, the overall sanctions enforcement environment in Spain has not been as active as in other EU Member States. However, in the context of Russia sanctions, there has been a slight uptick in enforcement actions. By…