In a 9 May press statement President von der Leyen announced that the EU is considering a proposed eleventh package of sanctions against Russia. This update provides an overview of those proposals and an update on sanctions-related civil litigation. Read more

In this post we provide a summary of a number of recent developments regarding the UK and EU sanctions imposed on Russia. Read more

On 21 March, the Office of Financial Sanctions Implementation ("OFSI") announced that all 1,730 targets of the UK's Russia-related asset freeze have also been designated for the purposes of the trusts restrictions. Read more

On 16 March, the UK's Office of Financial Sanctions Implementation ("OFSI") updated its guidance on monetary penalties and enforcement (the "Guidance") to set out its enforcement approach in cases involving ownership and control by designated persons. This is an issue which has assumed increased prominence during the past year with the escalation of sanctions against Russia and the huge number of additional asset freeze designations made as a result. This has resulted in many companies analysing whether their counterparties may be deemed to be "owned or controlled" by a sanctions target – a question to which there is often no easy answer. Read more

One year on from Russia's invasion of Ukraine, the UK and EU have announced additional sanctions measures against Russia, as summarised in this update. Additional US sanctions have also been announced (as summarised here), and the G7 issued a press release to reaffirm their commitment to strengthening the coordinated sanctions imposed against Russia to date. Read more

On February 24, 2023, the one-year anniversary of the Russian invasion of Ukraine, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced significant actions that targeted Russia’s financial services sector, sanctions evasions, Russia’s military supply chain, and metals and mining sector. Under the authority of Executive Order 14024, OFAC targeted the metals and mining sector and imposed sanctions on 22 individuals and 83 entities. OFAC also designated over 30 third-country individuals and companies connected to Russia’s sanctions evasion efforts, including those related to arms trafficking and illicit finance. Read more

The High Court has recently considered the impact of the UK sanctions against Russia on various aspects of litigation involving a sanctioned party: PJSC National Bank Trust v Mints [2023] EWHC 118 (Comm). Read more

The EU has previously announced that it intends to put in place a further package of Russian sanctions by 24 February 2023, to coincide with the one year anniversary of the invasion of Ukraine. In this briefing, we summarise the intended measures within that package and also provide a round-up of some other recent EU and UK developments. Read more