On March 2, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”), the U.S. Department of Justice (“DOJ”), and the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), issued a Tri-Seal Compliance Note, Cracking Down on Third-Party Intermediaries Used to Evade Russia-Related Sanctions and Export Controls (the “Note”), to … 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. UK Additional designations … Read more

The High Court has 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). The judgment raises important questions of law with wide implications for litigation involving sanctioned entities. The court’s key finding was that the UK sanctions do … 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 … Read more

On February 1, 2023, the United States Department of the Treasury’s (“Treasury Department”) Office of Foreign Assets Control (“OFAC”) imposed full blocking sanctions against twenty-two individuals and entities from multiple countries related to an alleged sanctions evasion network supporting Russia’s military activities. This action, taken pursuant to Executive Order (“E.O.”) 14024 was part of a … Read more

The Economic Crime and Corporate Transparency bill (the “Bill”), which is currently progressing through Parliament, is reportedly due to include provisions introducing a new failure to prevent offence affecting corporates, following statements by a UK Government minister during debates surrounding the Bill. In this briefing we outline the background to this development and anticipated next … Read more

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 … Read more

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. UK The Russia (Sanctions) (EU Exit) … Read more