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…
On April 18, 2024, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) and the UKās 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…