As part of the EU’s 12th package of sanctions against Russia, adopted on 19 December 2023 (see our previous blog post here), the EU introduced a requirement under Article 12g of Regulation 833/2014 which requires EU exporters to include wording in certain goods contracts prohibiting the re-export of the goods to Russia and providing for “adequate remedies” in the event of a breach, in order to combat the circumvention of EU export bans and more…
The leader of Russia’s political opposition, Alexei Navalny, died in a Siberian prison on February 16, just over a week before the two-year anniversary of Russia’s full-scale invasion of Ukraine on February 24. Both Navalny’s death and the anniversary of the invasion were cited as the motivations behind the latest rounds of sanctions against Russia. Members of our global sanctions team in our offices in the US, UK, Sweden, Australia, and Canada summarize the latest…
On 20 February 2024, the financial intelligence agencies of Canada (FINTRAC), Germany (FIU DE) and the Netherlands (FIU-NL) released a joint advisory regarding illegal procurement of dual-use goods by Russian end-users (Joint Advisory). Although primarily addressed to entities reporting under each country’s respective anti-money laundering (AML) regime, the Joint Advisory also is a useful resource for other companies seeking to comply with sanctions and export controls more generally, as it seeks to provide additional guidance…
On January 29, 2024, the US Department of the Treasury’s Office of Foreign Assets Controls (“OFAC”) revoked General License 43 (“GL 43”), which authorized certain transactions involving CVG Compania General de Mineria de Venezuela CA (“Minerven”). GL 43 was replaced with GL 43A to allow US Persons, through 12:01 a.m. eastern standard time, February 13, 2024, to wind down transactions involving Minerven (and entities it owns 50% or more) that were previously authorized by GL…