Herbert Smith Freehills recently hosted a webinar to discuss the way in which the recent Russian oil price cap measures will operate across the UK, EU and US and to consider the potential challenges that may arise for companies wishing to deal in Russian oil and those who provide related services.
The introduction of the first limb of the G7 Russian oil price cap represents yet another novel element of the sanctions imposed on Russia in response to the invasion of Ukraine. Rather than imposing outright bans on dealings with Russian oil, in September of this year the G7 introduced a plan to impose a cap on the price importers pay for Russian oil with a view to shrinking a key source of revenue used by Russia to finance the war. The oil price cap measures therefore ban the provision of services related to the seaborne transportation of Russian origin oil and oil products, unless purchased at or below the so-called price cap, thereby impacting importers of oil based in third countries which have not imposed sanctions on Russia where those importers rely on insurance cover and shipping services from UK, EU and US companies.
The price cap measures introduced by the UK, EU and US in respect of crude oil came into force on 5 December, with equivalent measures for petroleum products to follow on 5 February 2023.
A recording of the webinar is available here for those who were not able to join.
The last week has seen a further flurry of Russian sanctions activity, with both the UK and the EU introducing new restrictions. In this briefing we summarise the new UK restrictions, in particular the additional restrictions on the provision of services to Russia, and the EU’s ninth Russia sanctions package. Continue reading
On 7 December, the European Commission announced proposals for a ninth sanctions package against Russia. The measures are not yet in force and full details are not yet available, but we have summarised below the areas intended to be covered by the new package, along with a round-up of other UK and EU Russia sanctions developments. Continue reading
The UK introduced further sanctions against Russia on 4 November 2022, via the Russia (Sanctions) (EU Exit) (Amendment) (No. 16) Regulations 2022 (the “No. 16 Regulations”). These introduce further amendments to the Russia (Sanctions) (EU Exit) Regulations 2019 (the “Russia Regulations”). The amendments introduced by the No. 16 Regulations will come into force on 5 December 2022 (although, as set out below, certain specific measures will not take effect until February 2023) and introduce further measures relating to Russian oil, as discussed further in this briefing.
New UK Russia sanctions legislation was published on 28 October: the Russia (Sanctions) (EU Exit) (Amendment) (No. 15) Regulations 2022 (the “No. 15 Regulations”). These amend the UK’s principal Russia sanctions legislation: the Russia (Sanctions) (EU Exit) Regulations 2019 (the “Russia Regulations”). This briefing summarises the key amendments to the Russia Regulations, the majority of which came into force on 29 October. Continue reading
The FCA published today their long-awaited consultation paper on sustainability disclosure requirements and investment labels (the “Consultation“). This follows the discussion paper published in November 2021, which we summarised here.
The Consultation builds on the core elements of the regime outlined in the discussion paper: sustainable investment labels, consumer-facing disclosures, detailed product-level disclosures and entity-level disclosures. In addition, the Consultation also proposes naming and marketing rules with broader applicability, a general anti-greenwashing rule and other specific obligations on distributors.
In this post, we summarise our key takeaways from the Consultation, together with a high-level overview of the FCA’s proposals.
On 30 September, Foreign Secretary James Cleverly announced the imposition of a round of new UK sanctions against Russia. These restrictions are not yet in force.
Full details of the new measures had not been published at the time of writing, but we set out below a summary of the new restrictions as announced and will of course provide a further update when more information is available. Continue reading
This update contains a round-up of recent EU and UK Russia sanctions developments. In particular, we look at a raft of new UK sanctions legislation, as well as other developments in both jurisdictions. Continue reading
The UK voted to leave the European Union on 23 June 2016 and then officially ceased to be an EU Member State on 31 December 2020. Nearly five years later, the long drawn-out process of Brexit has still not come to an end, as the UK and EU continue to clash over borders and trade issues. For the financial services industry, all transitional periods are now over, and full compliance with the relevant local regime is a fact of life for those regulated or doing business in the UK or EU. The pain of separation continues to be felt: the capital markets and investment industries are naturally international, but issues of double compliance arise in many transactions, and fully liquid markets cannot be achieved where investors are subject to differing requirements.