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On October 30, 2024, the US Government imposed sanctions on hundreds of entities and individuals across the globe, primarily in response to Russia’s continued war in Ukraine, and amended US export controls related to Russia and Belarus. Below, we describe the key actions taken by the US Departments of the Treasury, State, and Commerce. 1. OFAC Actions With the aim of disrupting global sanctions evasion networks and domestic suppliers to Russia’s military-industrial base, the US…

On 30 September 2024, the UK Government issued a notice stating that from 31 October 2024, the provision of intra-group services will no longer be a specific licensing ground available in relation to professional and business services provided by UK companies to their Russian subsidiaries. Licence applications submitted before 31 October 2024 will not be affected by the change. Under Regulation 54C of The Russia (Sanctions) (EU Exit) Regulations 2019 (“UK Russia Regulations”), it is prohibited…

On 5 September 2024, the UK amended the scope of its Russia sanctions relating to the provision of certain legal advisory services to non-UK persons, as contained in Regulations 54D and 60DB of The Russia (Sanctions) (EU Exit) Regulations 2019 (“UK Russia Regulations”), via The Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2024 (the “Amending Regulation”). The Amending Regulation entered into force on 6 September 2024, in short (i) clarifying the knowledge a person must have…

On Saturday, April 20, 2024, after months of negotiations and many twists and turns, the US House of Representatives passed the 21st Century Peace through Strength Act (H.R. 8038). This bill, which is the fourth pillar of a broader foreign aid package to assist Israel, Ukraine, and the Indo-Pacific, contains numerous sanctions and trade-related national security measures. After each of the four foreign security bills were passed on Saturday, they were combined into one package…