The Office of Foreign Assets Control (“OFAC”) designated Open Joint Stock Company Rosneft Oil Company (“Rosneft”) and Public Joint-Stock Company Oil Company Lukoil (“Lukoil”) on October 22, 2025, in response to the ongoing war in Ukraine. In announcing the designations under Executive Order (“EO”) 14024, Secretary of the Treasury Scott Bessent stated that the actions were taken to advance the administration’s goal of ending the war in Ukraine by targeting two of Russia’s largest oil…
On 29 October 2025 and after more than three months, Switzerland finalized the implementation of the EU’s 18th sanctions package by updating the Ordinance on measures in connection with the situation in Ukraine (“Ukraine Ordinance”; see press release here). At the same day, the Federal Council also introduced new measures against Belarus by revising the Ordinance on measures against Belarus (“Belarus Ordinance”). These new measures (with one exception) entered into force on 30 October 2025…
In significant parallel actions this week, the EU and US imposed new sanctions on Russia. While the EU’s 19th sanctions package is much broader in scope, the measures overlap in their focus on the Russian energy sector, with the US imposing full blocking sanctions on Russia’s two largest oil majors, OJSC Rosneft Oil Company (“Rosneft”) and Lukoil OAO (“Lukoil”) and the EU imposing a full ban on Russia-origin liquified natural gas (“LNG”), among other energy sector…
In Japan, there were two major updates to its export control and sanction regime announced in the past few weeks. 1. Reimposition of Sanctions Against Iran On 29 September 2025, Japanese government announced the reimposition of the following measures under the Foreign Exchange and Foreign Trade Act, in response to United Nations Security Council Resolution 2231based on which sanctions against Iran concerning its nuclear issue under United Nations Security Council Resolutions 1737, 1747, 1803, and…