US Treasury, Commerce Department Sanction Hundreds of Individuals and Entities in Reaction to Navalny Death, Russian Invasion of Ukraine

On February 23, 2024, the US Treasury’s Office of Foreign Assets Control (“OFAC”) and the Commerce Department’s Bureau of Industry and Security (“BIS”) sanctioned nearly 300 individuals and entities in relation to their operations associated with Russia’s invasion of Ukraine. Together with actions from the US Department of State, this marks the largest number of … Read more


On February 1, 2024, the United States Department of Treasury’s Office of Foreign Assets Control (“OFAC”) published a Price Cap Coalition Compliance and Enforcement Alert (the “Alert”). Per the Alert, the “Price Cap Coalition,” which consists of the G7, the European Union, and Australia, has two key objectives: (1) constraining Russian revenues that could otherwise … Read more

The EU Anti Money Laundering Authority and the AML reform package: an update

In July 2021, the European Commission presented a package of legislative proposals designed to combat money laundering, terrorist financing and the evasion of sanctions. These proposals included the establishment of a new EU agency, the Anti Money Laundering Authority (AMLA). On 13 December 2023, the EU Parliament and Council of the EU announced that they had reached a “provisional agreement” on … Read more

OFSI publishes Annual Review 2022-23

On 14 December 2023, HM Treasury’s Office of Financial Sanctions Implementation (“OFSI“) published its Annual Review for the 2022-23 financial year (the “Annual Review“). As expected, the Annual Review predominantly focuses on the UK sanctions imposed against Russia following its invasion of Ukraine in February 2022. However, the publication also provides an overview of the other work … Read more

High Court dismisses force majeure and trade sanctions defences in breach of contract claim, and considers “ownership and control” test under UK sanctions

The High Court has allowed a summary judgment application in relation to a breach of contract claim, finding that there was no realistic prospect of the defendants being able to rely on force majeure and change of trade sanctions provisions in the agreement: Litasco SA v Der Mond Oil and Gas Africa SA & Anor (Rev1) [2023] … Read more


On December 20, 2023, the United States Department of Treasury’s Office of Foreign Assets Control (“OFAC”) tightened enforcement of the price cap on Russian oil. OFAC, in coordination with the Price Cap Coalition, updated the Guidance on Implementation of the Price Cap Policy for Crude Oil and Petroleum Products of Russian Federation Origin, implementing more … Read more

Sanctions tracker: UK creates new trade sanctions body and introduces new Russia sanctions restrictions

There have been a number of recent significant UK sanctions developments, including the announcement of the creation of a new Office of Trade Sanctions Implementation (“OTSI”) and the introduction of further Russia sanctions restrictions. We summarise these developments, and a round-up of other recent UK Russia sanctions news in this post. Since our last update … Read more

Proposed Regulations Clarify “FEOC” Compliance Requirements for 30D Clean Vehicle Tax Credits

On December 1, 2023, the Department of the Treasury (“Treasury”), and the Internal Revenue Service (“IRS”) issued REG-118492-23, a series of proposed regulations heightening the standards required for an important electric vehicle tax credit. Additionally, on December 4, 2023, the Department of Energy (“DOE”) published guidance, RIN 1901-ZA02, clarifying the application of Foreign Entity of … Read more

Ghost Fleet Update: OFAC Designates Additional Vessels, Companies

On December 1, 2023, the Office of Foreign Assets Control (“OFAC”) imposed sanctions on three entities and identified three vessels as blocked property that used G7 Price Cap Coalition services while carrying Russian crude oil above the Coalition-agreed price cap. These sanctions build on Treasury’s previous actions, most notably including letters recently sent to nearly … Read more