On 22 May 2026, the Swiss Federal Council announced the expansion of its sanctions lists against Russia and Belarus (see press release here). With this step, Switzerland has partially implemented the measures adopted by the EU under its 20th sanctions package. The corresponding amendments to the Ordinance on Measures in Connection with the Situation in Ukraine (“Ukraine Ordinance”) and the Ordinance on Measures against Belarus (“Belarus Ordinance”) entered into force on 22 May 2026. Following…
On 23 January 2026, the European Commission released new FAQ guidance providing clarifications for operators navigating the EU’s expanding Russia sanctions framework. Notably, the European Commission updated their Consolidated FAQs on Sanctions against Russia and Belarus (the “FAQs”, accessible here) with guidance on the Nord Stream transaction ban and the EU’s 19th sanctions package, summarized below. I. Clarifications on the Nord Stream Transaction Ban (Article 5af, Regulation 833/2014) The EU has published dedicated FAQs interpreting…
After publishing a draft implementing decree (Atto del Governo n. 317) (see our previous blog post here), Italy has now approved final legislation (Legislative Decree No. 211 of 30 December 2025) implementing Directive (EU) 2024/1226 which enter into force on 24 January 2026, significantly changing the criminal enforcement landscape in relation to EU sanctions violations. Legislative Decree No. 211/2025 increases criminal liability risks, particularly in respect of EU sanctions compliance, for companies (under Legislative Decree…
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…