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

On October 31, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) imposed additional sanctions related to Myanmar. In particular, OFAC issued Directive 1 pursuant to Executive Order (“E.O.”) 14014, which imposes extensive sanctions restrictions on Myanma Oil and Gas Enterprise (“MOGE”). In addition, OFAC designated additional individuals and entities in … Read more

On October 20, 2023, the Financial Crimes Enforcement Network (“FinCEN”) published an alert (the “FinCEN Alert”) to help assist financial institutions in identifying funding streams supporting the terrorist organization Hamas and reporting such activity to FinCEN. In the wake of the October 7, 2023 Hamas terrorist attack in Israel, the FinCEN Alert suggests that Hamas … 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

On October 18, 2023, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued multiple general licenses that suspend some sanctions, including those relating to oil and gas transactions with Venezuela’s state-owned oil company, Petroleos de Venezuela, S.A. (“PdVSA”) in response to the signing of an electoral roadmap agreement between the … 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