Background Article 8a of Council Regulation (EU) 833/2014 (the “EU Russia Regulations”) imposes obligations on EU parents to undertake “best efforts” to ensure that activities conducted by their non-EU subsidiaries do not undermine EU sanctions targeting Russia and Belarus. This requirement, which was introduced in June 2024, raises complex questions about the scope of EU sanctions and their applicability to the activities of non-EU entities. The Commission previously issued guidance in November 2024 in relation…
On 18 July 2025, the UK Government announced a lowering of the Oil Price Cap (“OPC”) to further inhibit Russia’s ability to use oil revenues to finance its illegal invasion of Ukraine. The OPC was first introduced in December 2022 to reduce Russia’s oil revenues in response to the invasion of Ukraine that same year. The OPC prevents G7 companies from shipping, insuring or servicing any Russian crude oil sold above the OPC price of…
In brief In recent years, intellectual property (IP) has become an increasingly important area of application for international sanctions. While sanctions have traditionally focused on restricting trade in goods, services, financial transactions and the movement of individuals, the scope has broadened to include intangible assets such as patents, trade secrets and software. This development reflects a growing recognition that IP rights are strategic assets that underpin critical technologies and industries. By restricting access to IP,…
On 21 July 2025, the UK government issued the General Trade Licence: Russia Sanctions – Sectoral Software and Technology (the “Sectoral Software Licence”) under Regulation 65 of the Russia (Sanctions) (EU Exit) Regulations 2019 (the “UK Russia Regulations”). The Sectoral Software Licence came into force on 21 July 2025 and will expire on 20 October 2025. The Sectoral Software Licence authorises providers located in or operating from within the UK and UK persons to transfer…