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…
On August 28, 2025, Canada announced amendments to the Special Economic Measures (Moldova) Regulations (the “Regulations”) sanctioning Russian collaborators in Moldova. The amendments list an additional sixteen individuals and two entities under the Schedule of the Regulations and took effect on August 28, 2025. These sanctions are announced in the context of Moldova’s upcoming parliamentary elections, which will be held on September 28, 2025, and are aimed at individuals who are stated to have been actively participating in…
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…
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…