On 10 January 2025, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and the UK’s Office of Financial Sanctions Implementation (“OFSI”) announced the designations of two major Russian oil companies, PJSC Surgutneftegas and Gazprom Neft. The US and the UK have introduced new general licenses to permit limited activity relating to these entities, detailed further below. OFAC also designated numerous energy sector parties and issued a new Russia-related petroleum services prohibition.…
On 7 January 2025, the UK’s Office of Trade Sanctions Implementation (“OTSI”) published two guidance documents on compliance with the UK’s sanctions against Russia, focusing on combatting sanctions evasion and on incorporating “no Russia” clauses in customer contracts. The new guidance documents aim to support UK businesses in understanding and mitigating the risks associated with Russian sanctions evasion, by providing guidance on understanding circumvention practices and recommendations for mitigation steps, including incorporating protective “no Russia”…
On 16 December 2024, the EU introduced its 15th package of sanctions against Russia, including by amending Regulation (EU) 833/2014 and Regulation (EU) 269/2014. The EU also issued the first designations under its “hybrid threats” sanctions framework, which was announced in early October 2024. Finally, the EU designated individuals and entities pursuant to EU sanctions against Belarus (Regulation (EC) No 765/2006). This latest round of sanctions entered into force on 17 December 2024 and is…
On November 21, 2024, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated dozens of Russian banks, including Gazprombank and other Russian banks, securities registrars, and finance officials, to the List of Specially Designated Nationals and Blocked Persons (“SDN List”). The full SDN designation of Gazprombank, the largest remaining Russian bank, is particularly notable given its role in supporting gas flows between Russia and remaining European and other customers. On the…