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…
Background The European Union continues to expand its sanctions regime against Russia and Belarus. The latest – the 18th – EU Russia/Belarus sanctions package was published on 19 July 2025, and included a range of additional sanctions, mainly targeting the Russian energy, banking and military industries, but also individuals and the Russian shadow fleet (see our previous blog post on the 18th sanctions package). EU sanctions against Russia are enacted in the form of regulations,…
On 18 July 2025, the European Union adopted its 18th package of sanctions against Russia, including by amending Regulation (EU) 833/2014 and Regulation (EU) 269/2014. The EU also mirrored a number of measures and introduced additional designations in its Belarus sanctions by amending Regulation (EC) 265/2006. Adopted just two months after the 17th package, this latest round of measures reflects the EU’s continued strategic shift toward more dynamic, extraterritorial, and asset-specific sanctions and reinforces the…