Sanctions Tracker – Department of Foreign Affairs and Trade to review Australia’s Autonomous Sanctions Framework

    On 30 January 2023, the Department of Foreign Affairs and Trade (DFAT) announced the Australian Sanctions Office (ASO) will lead a comprehensive review of Australia’s legal framework for autonomous sanctions which includes the Autonomous Sanctions Act 2011 (the Act), Autonomous Sanctions Regulations 2011 (Cth) (Regulations) and 18 legislative instruments made pursuant to the Act and Regulations (together, Sanctions Framework). The review has been commissioned as parts of the Sanctions Framework are set to expire on 1 April 2024. Read more

    OFAC Releases New Iran Internet Guidance

    On January 11, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a new Iran-related “Frequently Asked Question” (“FAQ”) (available here) regarding the implementation of Iran General License (“GL”) D-2, issued by OFAC on September 23, 2022.  In addition to this new FAQ, OFAC also amended over twenty already published … Read more

    OFAC Issues Additional Price Cap Guidance

    On December 30, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control’s (“OFAC”) issued preliminary guidance on the implementation of the price cap policy for Russian-origin petroleum products (the “Petroleum Products Guidance”). The Petroleum Products Guidance is available here. The U.S. and other countries recently imposed a price cap related to Russian-origin … Read more

    Corporate Crime Webinar – G7 Russian oil price cap

    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

    U.S. Department of Treasury Sanctions Announcement

    On December 9, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced sanctions on, among others, over 40 individuals and entities in North Korea (DPRK), El Salvador, Guatemala, Guinea, Iran, Mali, the Russian Federation, and China (PRC). In its announcement, OFAC stated that it utilized various tools and authorities—including Executive … Read more

    Sanctions tracker – UK and EU introduce new Russian sanctions

    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

    Webinar: G7 Russian oil price cap

    Webinar Series Friday 16 December 2022, 12.00 – 1.00pm UK time Last week we saw the introduction of the first limb of the G7 Russian oil price cap, representing 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, … Read more

    Sanctions tracker: EU announces ninth Russia sanctions package

    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. EU … Read more

    OFAC Releases Price Cap Determination and Guidance on the Implementation of Price Cap Policy on Crude Oil Originating in the Russian Federation

    On November 22, 2022, the U.S. Office of the Treasury’s Office of Foreign Assets Control (“OFAC”) released a Determination pursuant to Executive Order 14071, “Prohibiting New Investment in and Certain Services to the Russian Federation in Response to Continued Russian Federation Aggression.” The Determination states that E.O. 14071 will apply to trading and commodities brokering, … Read more