In recent weeks, there have been a number of noteworthy developments highlighting the increasing focus that US, EU, UK and other governments are placing on the potential circumvention of sanctions against Russia, and the roles of third countries and companies in facilitating the circumvention or undermining of such sanctions measures. These anti-circumvention efforts are taking place in the context of the G7’s concerted effort to bolster sanctions enforcement around the world, through the creation of…
The UK has announced a new package of sanctions against Russia. This will include the following sanctions: Export bans on every item Russia has been found using on the battlefield to date. Goods will include aircraft parts, radio equipment, and electronic components that can be used by the Russian military industrial complex, including in the production of UAVs. Import bans on 140 goods including iron and steel products processed in third countries. Extension of existing…
In December 2022, the United Nations Security Council (the ‘UNSC’) adopted a resolution which introduced a standardised humanitarian exemption across UN regimes according to which activities necessary for humanitarian assistance and other activities that support basic human needs are exempt from sanctions in the form of asset freezes imposed by the Security Council or by its Sanctions Committees. All UN sanctions regimes except the Afghanistan regulations will now include a standardised humanitarian exception to the…
On February 9, 2023, the United States and the United Kingdom designated seven Russian individuals that have been associated with the development or deployment of a range of ransomware strains which have targeted the UK and the US. This is the first time that the UK has made designations under its Cyber (Sanctions) (EU Exit) Regulations 2020. The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued this press release in tandem…