On 5 September 2024, the UK amended the scope of its Russia sanctions relating to the provision of certain legal advisory services to non-UK persons, as contained in Regulations 54D and 60DB of The Russia (Sanctions) (EU Exit) Regulations 2019 (āUK Russia Regulationsā), via The Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2024 (the āAmending Regulationā). The Amending Regulation entered into force on 6 September 2024, in short (i) clarifying the knowledge a person must have…
On August 23, 2024, the eve of Ukraine’s Independence Day (August 24, 2024), the US Departments of Commerce and Treasury issued new export controls and sanctions in response to Russia’s invasion of Ukraine. The new controls target the procurement networks who support Russia’s war on Ukraine and its military industrial complex and payment channels. The Commerce Department’s Bureau of Industry and Security (“BIS”) made the following changes to the Export Administration Regulations (“EAR”) and…
The Middle East is an increasingly important jurisdiction for Western governments from a Russia sanctions foreign policy perspective, as there is a perception that increased trade flows between the Middle East and Russia means that Western sanctions are effectively being circumvented. Companies in the Middle East may have concerns about triggering EU / UK / US sanctions jurisdiction, or being directly designated by Western governments for engaging in activities deemed to be contrary to the…
On Monday 27 May 2024, the EU established a new sanctions framework for the implementation of restrictive measures against those responsible for serious human rights violations or abuses, for the accelerating and systematic repression of civil society and democratic opposition, and for undermining democracy and the rule of law in Russia. As set out in Council Decision (CFSP) 2024/1484 and Council Regulation (EU) 2024/1485 (āRussia Human Rights Regulationā). In its press release (here), the European…