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Earlier this month, the G7 announced a plan to impose a cap on the price importers pay for Russian oil (see our previous blogpost for further detail). On 28 September, President von der Leyen made a statement regarding the EU’s intended implementation of this plan, as part of an eighth sanctions package in response to the escalation of the … Read more
As readers of this blog are aware, in our regular ‘sanctions tracker’ we focus on updating clients on new sanctions developments. Nearly six months on from Russia’s invasion of Ukraine, there is also a developing body of experience regarding the practical impact of the sanctions measures in a number of different fields. One area where the … Read more
As US toughens CFIUS oversight of foreign investments in sensitive sectors of the economy, we assess the key factors in play President Biden recently issued an Executive Order on Ensuring Robust Consideration of Evolving National Security Risks by the Committee on Foreign Investment in the United States (the Foreign Investment EO). It directs increased scrutiny by the Committee … Read more
Our previous blog post discussed the G-7’s recent proposal to impose a price cap on Russian oil in an effort to diminish the energy revenues of the Russian state. In this post, we examine the new guidance issued by the U.S. Department of the Treasury (“Treasury”), Office of Foreign Assets Control (“OFAC”) establishing a framework … Read more
The finance ministers from the Group of Seven major economies (“G-7”) have issued a plan to impose a cap on the price importers pay for Russian oil, in a bid to shrink a key source of revenue the Kremlin uses to finance its war in Ukraine. As described in the G-7 statement, the G-7 countries, … Read more
In this mini-series, we discuss the recent sanctions measures implemented in the U.S., E.U., and U.K. as a response to the crisis in Ukraine. In this episode, Jonathan Cross, Susannah Cogman, and Brittany Crosby-Banyai focus on the recent sanctions measures that impact Russian investments. Read more
On July 27, 2022, the US Senate unanimously passed a nonbinding, bipartisan resolution to designate the Russian Federation as a “State Sponsor of Terrorism” (SST). In parallel, a bipartisan group of members of the US House of Representatives introduced a bill on July 28, 2022 to designate Russia as an SST. See H.R.8568. These actions … Read more
Our previous blogpost mentioned the recent red alert on sanctions evasion typologies issued by various law enforcement and financial sector partners. In this post we look at this update in more detail to identify potential indicators of sanctions evasion, and the steps that the alert indicates that financial sector and other anti-money laundering (“AML”) regulated firms should … Read more
The U.S. government has continued to impose additional Russia-related sanctions measures in response to Russia’s invasion of Ukraine. We previously discussed Russia-related sanctions and export control measures imposed by the U.S. on July 7, July 6, June 13, and in earlier posts. In the U.S. Department of the Treasury’s Office of Foreign Assets Control’s (“OFAC”) … Read more
