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UK Imposed Sanctions

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On 23 April 2025, the UK government published the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2025, which took effect on 24 April 2025. These new regulations amended the Russia (Sanctions) (EU Exit) Regulations 2019 to introduce additional trade restrictions, focusing on export and import prohibitions, technology, and software transfers. We have set out summaries of the key new measures below. Sectoral Software The amending regulations introduce prohibitions on making available and transferring “sectoral software” to…

In a context of increasing trade barriers to Brazilian exports, especially the additional tariffs imposed by the United States (US Reciprocal Tariffs) that include Brazilian exports, in addition to environmental restrictions on the export of Brazilian products by the European Union and other countries (such as the Carbon Border Adjustment Mechanism (CBAM) and other carbon control mechanisms (e.g. UK CBAM), imposed by the European Union and other countries), Law No. 15.122/2025 (known as the “Economic Reciprocity Law”)…

On 21 March 2025, the UK Office of Financial Sanctions Implementation (“OFSI”) published its 2023-2024 annual review (see here). The report summarises OFSI’s activities for the 2023-24 financial year in the context of its aim to “Engage, Enhance, Enforce”. This involves industry engagement to improve understanding of UK sanctions, enhancing stakeholder service through increased hiring and investment, and enforcing compliance using a full range of actions and improved processes. Although OFSI’s report indicates that the…

On 24 February 2025, the third anniversary of Russia’s further invasion of Ukraine, the UK Government announced 107 new designations targeting individuals, businesses (including several state-owned entities), government officials and vessels in what it labelled its most extensive set of sanctions against Russia since the start of the invasion. According to the UK Foreign, Commonwealth, and Development Office (“FCDO”) press release, this package is aimed at weakening Russia’s military supply chains, revenues fuelling the war…