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Sanctions Regimes

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On 18 December 2023, the EU published its 12th package of sanctions targeting Russia. The changes implemented in this package have a material impact on all businesses with a continued or residual presence in Russia, including those seeking to exit and divest from Russia. Moreover, all companies, even those not trading directly with Russia, should be mindful of the increased focus on targeting circumvention.In our latest on-demand webinar, we provide you with an overview of some…

What happened? On January 17, 2024, the US State Department (“State”) announced the designation of Ansarallah, commonly known as the Houthis, as a Specially Designated Global Terrorist (“SDGT”) pursuant to Executive Order 13224. The designation will be effective on February 16, 2024, at which time the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) will add Ansarallah to the list of Specially Designated Nationals and Blocked Persons (“SDN List”). In other words, the designation…

On December 22, 2023, President Biden signed into law the National Defense Authorization Act (“NDAA”) for Fiscal Year 2024 (P.L. 118-31). A must-pass piece of legislation that funds Department of Defense (“DoD”) operations on an annual basis, the NDAA is a frequent vehicle for trade-related provisions and legislative changes affecting DoD acquisition policies with direct implications for government contractors. The measure includes a number of provisions relating to US export controls, sanctions, and supply chain…

On 26 December 2023, China’s Ministry of Foreign Affairs announced new sanctions measures under the Anti-Foreign Sanctions Law against the following parties for their involvement in the imposition of US restrictive measures on Chinese entities over their links to alleged human rights abuses in the Xinjiang Uygur Autonomous Region: US data intelligence firm, Kharon; Edmund Xu, research director of Kharon; and Nicole Morgret, a former human rights analyst at the Centre for Advanced Defence Studies.…