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Sanctions Regimes

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On 17 July 2025, the UK Office of Financial Sanctions Implementation (“OFSI”) launched a series of new online forms for parties looking to submit licence applications or report information such as suspected breaches of financial sanctions.   The new forms aim to streamline the submission process and to avoid incomplete or incorrect submissions through the introduction of mandatory fields and built-in guidance notes, thereby reducing the need for follow-up questions and enabling OFSI to provide…

On June 30, 2025, President Trump issued Executive Order 14312 (the “Syria EO”) terminating the U.S. comprehensive sanctions program targeting Syria, while also continuing to maintain and expand certain sanctions targeting former Syrian President Bashar al-Assad and others associated with the former Syrian regime. In addition, the U.S. State Department revoked the designation of Hay’at Tahrir al-Sham’s (“HTS”) as a Foreign Terrorist Organization (“FTO”) on July 8, 2025. OFAC has taken the following actions to implement…

On July 1, 2025, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published the International Criminal Court-Related Sanctions Regulations to implement Executive Order (“EO”) 14203, “Imposing Sanctions on the International Criminal Court”, issued on February 6, 2025. EO 14023 authorized sanctions on foreign persons engaged in certain efforts by the International Criminal Court (“ICC”) to target the United States and Israel. EO 14023 In EO 14203, President Trump finds that the ICC…

The EU Commission has issued a factsheet shedding light on the relationship between Incoterms and EU sanctions compliance. It makes clear that the Incoterms “Ex Works” rule—which shifts responsibility and risk to the importer/buyer from the moment of collecting the goods—does not exempt EU-based exporters or sellers from their legal obligations under EU sanctions law. The Commission underscores that adherence to EU sanctions is mandatory for all individuals and entities under EU jurisdiction, regardless of…