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…
Earlier this year, the EU introduced various new restrictions as part of its sanctions packages targeting Russia (see our blog post on the 14th EU Russia sanctions package) and Belarus (see our blog post of the most recent EU Belarus sanctions package). Among the notable and novel restrictions were: Businesses should therefore review their current practices and consider whether any enhancements are necessary to comply with these measures. Guidance on “best efforts” obligations The “best…
On 7 November 2024, the UK government designated an additional 56 individuals and entities in its largest financial sanctions package since May 2023 (see the official press release here). The package aims to further restrict the supply of equipment utilised by Russia’s military industrial complex and target Russia’s global activities, particularly in Africa. Newly adopted designations The package consists of 56 new designations through five of the UK’s autonomous sanctions regimes. Targets include: These individuals…
On 30 September 2024, the UK Government issued a notice stating that from 31 October 2024, the provision of intra-group services will no longer be a specific licensing ground available in relation to professional and business services provided by UK companies to their Russian subsidiaries. Licence applications submitted before 31 October 2024 will not be affected by the change. Under Regulation 54C of The Russia (Sanctions) (EU Exit) Regulations 2019 (“UK Russia Regulations”), it is prohibited…