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Sanctions Targeting Russia

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Just before the holidays, President Biden signed two bills passed in the final days of the last Congress that contain a number of provisions with implications for sanctions, export controls, and supply chain restrictions: On December 23, 2022, President Biden signed into law the National Defense Authorization Act (“NDAA”) for Fiscal Year 2023 (P.L. 117-263). The measure includes a number of provisions relating to US export controls, sanctions, and related subjects, including additional sanctions targeting…

According to press report by “Rzeczpospolita”, Poland’s leading business and legal daily, senior diplomats from Poland and Lithuania have anonymously revealed certain elements of the two countries’ joint negotiating position in relation to the tenth package of EU sanctions against Russia and Belarus. Per the press report, the proposals by Poland and Lithuania include the following: Restrictions on Russia’s nuclear sector, including the designation of Rosatom and/or its executives (a move that has so far…

In the last month of 2022, Switzerland implemented further EU sanctions measures against the Russian Federation. In summary, Switzerland adopted the following amendments: On 8 December 2022, the Federal Department of Economic Affairs, Education and Research (EAER) amended Annexes 7, 8, 18, and 28 of the Ordinance on Measures connected with the Situation in Ukraine (the “Ordinance“).On 16 December 2022, the Federal Council amended the measures on trade, brokering and transport of crude oil and…

On December 30, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued “Preliminary Guidance on Implementation of the Price Cap Policy for Petroleum Products of Russian origin” to explain how OFAC will implement a ban on the provision of services related to the maritime transportation of Russian-origin petroleum products (“Petroleum Products Guidance”). The petroleum products ban builds on a similar ban related to maritime transportation of Russian-origin crude oil that…