The Biden Administration issued another round of sanctions against Russia in its final days, with less than a week left in the Administration. This followed on the heels of major sanctions imposed by OFAC on Russia’s energy sector just five days prior – see our blog post on that development here. Specifically, on January 15, 2025, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and the US Department of State (“State”)…
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…