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 (“Russia Human Rights Regulation”). In its press release (here), the European…
On April 18, 2024, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) and the UK’s Foreign, Commonwealth & Development Office (“FCDO”) announced a coordinated sanctions package targeting Iran. In the US, OFAC added 16 individuals and 10 entities to the Specially Designated Nationals and Blocked Persons List (“SDN List”) and the US Commerce Department’s Bureau of Industry and Security (“BIS”) also expanded the scope of Foreign Direct Product (“FDP”) rules for foreign-produced items…
On April 24, 2024, President Biden signed into law a national security package (H.R. 815) that includes the 21st Century Peace through Strength Act, the fourth pillar of a broader foreign aid package to assist Israel, Ukraine, and the Indo-Pacific. The law contains numerous sanctions and trade-related provisions. In this blog post, we are summarizing the provisions that are most relevant to multinational companies seeking to comply with applicable trade rules and mitigate risks, which…