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Sanctions Regimes

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On 18 December 2023, the EU published its 12th package of sanctions targeting Russia via Regulation (EU) 2023/2878 and Regulation (EU) 2023/2875, amending Regulation (EU) 833/2014 and Regulation (EU) 269/2014, respectively (collectively, “12th EU Russia Sanctions Package”). The amendments to Regulation (EU) 269/2014 (related to Designated Persons (“DPs”)) are effective immediately while the amendments to Regulation (EU) 833/2014 become effective today, 19 December 2023. These amendments have a material impact on all businesses with a…

On August 23, 2023, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued the first Determination Pursuant to Section 1(a)(i) of Executive Order (“EO”) 14014 (the “Determination”), which extends the application of section 1(a)(i) of EO 14014 to the jet fuel sector of the Burmese economy. On the same day, OFAC also published two related Frequently Asked Questions (“FAQs”): FAQ 1132 and FAQ 1133. Our blog post on the issuance of EO 14014…

On 18 July 2023, the Dutch Fiscal Intelligence and Investigation Service (FIOD) published a statement that it had recently arrested a Dutch citizen in an ongoing investigation into suspected circumvention of EU sanctions against Russia. As part of the investigation, the FIOD also seized the business inventory and digital and physical administration of the suspect and his company. The arrested individual is suspected of exporting computers and computer parts to Russia in violation of EU sanctions.…

On 28 June 2023, the US Bureau of Industry and Security (“BIS”) announced that the “Five Eyes” countries (Australia, Canada, New Zealand, the United Kingdom and the United States) have agreed to formally coordinate on export control enforcement, with a particular emphasis on the export controls targeting Russia and Belarus, which have been a core tool in the broader sanctions toolbox. Baker McKenzie has deep export controls expertise in four of the Five Eyes countries: …