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Sanctions Regimes

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As a first step towards implementing the EU’s 18th sanctions package, the Swiss government amended several annexes to the Ordinance on Measures in Connection with the Situation in Ukraine (“Ukraine Ordinance”) on 11 August 2025. The Swiss government also extended the lists of designated persons in the Ordinance on Measures against Belarus (“Belarus Ordinance”) and the Ordinance on Measures against Moldova (“Moldova Ordinance”), following the listings adopted by the EU on 18 and 15 July…

On 18 July 2025, the UK Government announced a lowering of the Oil Price Cap (“OPC”) to further inhibit Russia’s ability to use oil revenues to finance its illegal invasion of Ukraine. The OPC was first introduced in December 2022 to reduce Russia’s oil revenues in response to the invasion of Ukraine that same year. The OPC prevents G7 companies from shipping, insuring or servicing any Russian crude oil sold above the OPC price of…

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 31 July 2025, the UK Office of Financial Sanctions Implementation (“OFSI”) announced that it had imposed a monetary penalty totalling GBP 300,000 on Markom Management Limited (“MML”), a provider of fiduciary, management, administration, bookkeeping and accounting services incorporated in the UK. The monetary penalty related to conduct in 2018 and a breach of the UK’s pre-Brexit sanctions regime, specifically the UK’s implementing regulations for Council Regulation (EU) No 269/2014 (Ukraine Misappropriation and Human Rights)…