On 12 October 2023, the Price Cap Coalition (Australia, Canada, the European Union, France, Germany, Italy, Japan, the United Kingdom, and the United States) renewed efforts to ensure effective enforcement of the price cap on Russian-origin oil and petroleum products. Below we summarize the Price Cap Coalition’s joint advisory for the maritime oil industry and other actions taken by the United States. Maritime Oil Industry Advisory The Price Cap Coalition issued an advisory providing seven…
The UK’s Office of Financial Sanctions Implementation (“OFSI”) has published updated guidance (the “Russia Sanctions Guidance”) on the implementation of the Russia (Sanctions) (EU Exit) Regulations 2019 (“UK Russia Regulations”), including a new FAQ addressing circumstances where a UK financial institution receives funds indirectly from or via a designated bank. In parallel with this update to its Russia Sanctions Guidance, OFSI has also published a new General Licence relating to Correspondent Banking Payments (INT/2023/3566356). Updated…
On 22 August, it was reported that the UK Government is considering the proscription of the Wagner group as a terrorist organisation under the Terrorism Act 2000. The Wagner group is a collection of individuals and entities globally making up the ‘Wagner Network’, which is engaged in military, economic, political, and influencing operations. They are known for being a private military company. Proscribing Wagner as a terrorist organisation would put it in the same legal…
On 29 June 2023, the UK introduced further restrictions to The Russia (Sanctions) (EU Exit) Regulations 2019 (“UK Russia Regulations”) through the Russia (Sanctions) (EU Exit) (Amendment) (No. 3) Regulations 2023 (the “Amending Regulation”). The principal change enacted by the Amending Regulation is the introduction of restrictions on the provision of certain legal advisory services, which entered into force on 30 June 2023. The Amending Regulation prohibits the direct or indirect provision of legal advisory…