Background The European Union continues to expand its sanctions regime against Russia and Belarus. The latest – the 18th – EU Russia/Belarus sanctions package was published on 19 July 2025, and included a range of additional sanctions, mainly targeting the Russian energy, banking and military industries, but also individuals and the Russian shadow fleet (see our previous blog post on the 18th sanctions package). EU sanctions against Russia are enacted in the form of regulations,…
On 31 July 2025, the UK Office of Financial Sanctions Implementation (“OFSI”) announced that it had imposed a monetary penalty totalling GBP 300,000 on Markom Management Limited (“MML”), a provider of fiduciary, management, administration, bookkeeping and accounting services incorporated in the UK. The monetary penalty related to conduct in 2018 and a breach of the UK’s pre-Brexit sanctions regime, specifically the UK’s implementing regulations for Council Regulation (EU) No 269/2014 (Ukraine Misappropriation and Human Rights)…
At the Annual Compliance conference recently held in London, Baker McKenzie hosted a session on ‘The evolving national security, sanctions and export controls landscape’. This session introduced the concept of the “trade toolbox” — a growing set of measures designed to manage national security risks through trade and investment restrictions. Speakers highlighted the increasing complexity of global compliance, particularly in relation to business relating to China, Russia, and in the Middle East. China: outbound investment,…
The EU Commission has issued a factsheet shedding light on the relationship between Incoterms and EU sanctions compliance. It makes clear that the Incoterms “Ex Works” rule—which shifts responsibility and risk to the importer/buyer from the moment of collecting the goods—does not exempt EU-based exporters or sellers from their legal obligations under EU sanctions law. The Commission underscores that adherence to EU sanctions is mandatory for all individuals and entities under EU jurisdiction, regardless of…