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EU Imposed Sanctions

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In significant parallel actions this week, the EU and US imposed new sanctions on Russia. While the EU’s 19th sanctions package is much broader in scope, the measures overlap in their focus on the Russian energy sector, with the US imposing full blocking sanctions on Russia’s two largest oil majors, OJSC Rosneft Oil Company (“Rosneft”) and Lukoil OAO (“Lukoil”) and the EU imposing a full ban on Russia-origin liquified natural gas (“LNG”), among other energy sector…

Following the EU’s 18th sanctions package and the latest developments of the UK’s sanctions against Russia, the Governments of Australia and Japan also introduced additional measures against Russia respectively on 18 and 12 September 2025. Among other measures, they have agreed with other G7 countries to phase out Russian oil imports in response to the 2022 invasion of Ukraine, indicating aligned efforts within the G7 with respect to the imposition of sanctions against Russia. This…

There have been a number of fluctuating developments in the UN and EU’s approach to Iran over the past few weeks, with a further attempt to salvage negotiations in an agreement on 10 September. We set out further details herein, including consideration of the sanctions implications. Political Developments At the end of August, amid concerns regarding Tehran’s continued resistance to international nuclear oversight and Russia’s upcoming presidency of the United Nations Security Council, the E3…

Background Article 8a of Council Regulation (EU) 833/2014 (the “EU Russia Regulations”) imposes obligations on EU parents to undertake “best efforts” to ensure that activities conducted by their non-EU subsidiaries do not undermine EU sanctions targeting Russia and Belarus. This requirement, which was introduced in June 2024, raises complex questions about the scope of EU sanctions and their applicability to the activities of non-EU entities. The Commission previously issued guidance in November 2024 in relation…