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Sanctions Targets

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On December 11, 2023, the US Departments of Commerce, the Treasury, Justice, State, and Homeland Security issued a “Quint-Seal” Compliance Note titled Know Your Cargo: Reinforcing Best Practices to Ensure the Safe and Compliant Transport of Goods in Maritime and Other Forms of Transportation (“Note”). The Note is directed at the maritime and other transportation industries—including transportation companies, maintenance companies, insurance providers, financial institutions, and “other entities involved in funding and facilitating the transport of…

On December 22, 2023, the Biden Administration issued a new Executive Order (“EO”) “Taking Additional Steps with Respect to the Russian Federation’s Harmful Activities” (the “December 22 EO”) amending EO 14024 of April 15, 2021 (“Blocking Property With Respect To Specified Harmful Foreign Activities of the Government of the Russian Federation”) and EO 14068 of March 11, 2022 (“Prohibiting Certain Imports, Exports, and New Investment With Respect to Continued Russian Federation Aggression”). According to a…

On 14 December 2023, the Office of Financial Sanctions Implementation (“OFSI”) published its 2022-2023 annual review (see here). The review summarises OFSI’s activities over the 2022-2023 financial year and looks ahead at trends and OFSI’s priorities for the next year. Russia Sanctions The report has a particular focus on the UK’s expanded Russia sanctions regime, stating that by 31 March 2023, “130 oligarchs and family members” who had a combined net worth of around £145…

On 18 December 2023, the EU published its 12th package of sanctions targeting Russia via Regulation (EU) 2023/2878 and Regulation (EU) 2023/2875, amending Regulation (EU) 833/2014 and Regulation (EU) 269/2014, respectively (collectively, “12th EU Russia Sanctions Package”). The amendments to Regulation (EU) 269/2014 (related to Designated Persons (“DPs”)) are effective immediately while the amendments to Regulation (EU) 833/2014 become effective today, 19 December 2023. These amendments have a material impact on all businesses with a…