On 11 February 2025, we saw the first public multi-jurisdictional coordinated sanctions action under the Trump Administration when the United States, Australia, and the UK announced joint sanctions against alleged key members of a Russian cybercrime supply chain. This action was taken by the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), Australia’s Department of Foreign Affairs and Trade, and the UK Foreign Commonwealth and Development Office (“UK FCDO”). See the US…
On 10 January 2025, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and the UK’s Office of Financial Sanctions Implementation (“OFSI”) announced the designations of two major Russian oil companies, PJSC Surgutneftegas and Gazprom Neft. The US and the UK have introduced new general licenses to permit limited activity relating to these entities, detailed further below. OFAC also designated numerous energy sector parties and issued a new Russia-related petroleum services prohibition.…
On 8 January 2025, the UK Government announced the forthcoming launch of a new sanctions regime targeting irregular migration and organised immigration crime, expected to come into force in 2025. The UK Government explained, in an 8 January press release, that this new sanctions regime is designed to target organised immigration networks operated and utilised by people smugglers, with the goal of deterring smugglers and stemming their financial flows at their source. This forms part…
On 7 January 2025, the UK’s Office of Trade Sanctions Implementation (“OTSI”) published two guidance documents on compliance with the UK’s sanctions against Russia, focusing on combatting sanctions evasion and on incorporating “no Russia” clauses in customer contracts. The new guidance documents aim to support UK businesses in understanding and mitigating the risks associated with Russian sanctions evasion, by providing guidance on understanding circumvention practices and recommendations for mitigation steps, including incorporating protective “no Russia”…