On November 2, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated 130 new Russian entities and individuals that OFAC identified as supporting Russia’s war in Ukraine by “providing Russia with much-needed technology and equipment from third countries.” On the same day, the U.S. Department of State issued nearly 100 … Read more

In R. (on the application of Mikhail Fridman) v HM Treasury [2023] EWHC 2657 (Admin) the High Court dismissed all grounds of challenge raised by an individual designated under the sanctions regime. In doing so the court made comments on the proper role of judicial review and evidence in such proceedings, in keeping with the recent trend … Read more

In an ongoing effort to respond to the Russian invasion of Ukraine, the Australian Government continues to broaden its sanction regime against Russia. Notably, the government has turned its focus on declaring a ban on the export of machinery and related parts to Russia and areas of Ukraine currently under Russian control as foreshadowed earlier … Read more

Our previous briefing commented on the recent Court of Appeal decision in Mints v PJSC National Bank Trust [2023] EWCA Civ 1132 and, particularly, the court’s consideration of the “ownership and control” test under the UK sanctions regime. In summary, the court concluded that there was no carve-out to the ownership and control test for control exercised through political office … Read more

On October 12, 2023, the Russian oil Price Cap Coalition (consisting of the G7 countries, the European Union, and Australia) issued an advisory (the “Advisory”) for the maritime oil industry and related sectors to provide recommendations concerning specific best practices in the maritime oil industry. The Price Cap Coalition’s members have agreed to restrict a … Read more

The Court of Appeal has confirmed that UK sanctions do not preclude the entry of judgments in favour of Russian sanctioned parties: Mints v PJSC National Bank Trust [2023] EWCA Civ 1132. The court also held that the Office of Financial Sanctions Implementation (OFSI) is entitled to license a sanctioned party to pay an adverse costs order, … Read more

On September 27, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) sanctioned five entities and two individuals based in the Islamic Republic of Iran (“Iran”), the People’s Republic of China (“China”), Hong Kong, Türkiye, and the United Arab Emirates (“UAE”) involved in the procurement of sensitive parts for Iran’s one-way … Read more

In this post, we provide a round-up of key recent Russia sanctions developments in the UK and EU, including the findings from the Financial Conduct Authority’s (“FCA”) review of firms’ sanctions controls. UK FCA review of sanctions systems and controls On 6 September, the FCA published the results of a recent programme to assess the systems and … Read more