The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 24 Mar 2025 (EU):
The Akin Summary document has now been posted for this action.
The European Commission (the "Commission") issued new Russia sanctions FAQs relating to LNG transshipments to, amongst other things, offer further guidance on EU sanctions measures under Article 3r of Council Regulation (EU) 833/2014 ("Regulation 833").
- 24 Mar 2025 (UK):
The Akin Summary document has now been posted for this action.
The Office of Financial Sanctions Implementation ("OFSI") amended UK General Licence INT/2022/2085212 (the "GL") to remove Rosbank PJSC from, and add TBank to, the definition of "Sanctioned Banks", pursuant to Regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019.
- 24 Mar 2025 (UK):
The Akin Summary document has now been posted for this action.
The Office of Financial Sanctions Implementation ("OFSI") amended UK General Licence INT/2022/1947936 (the "GL") to remove Rosbank PJSC from, and add TBank to, the definition of "Designated Financial Institution", pursuant to Regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019 (the "Russia Regulations").
- 20 Mar 2025 (UK):
The Akin Summary document has now been posted for this action.
The Office of Financial Sanctions Implementation ("OFSI") announced that, in accordance with section 146 of the Policing and Crime Act 2017, a monetary penalty of £465,000 has been imposed against UK registered Herbert Smith Freehills CIS LLP Moscow ("HSF Moscow") for six payments made in breach of the UK's Russia (Sanctions) (EU Exit) Regulations 2019 ("Russia Regulations"). According to OFSI's Penalty Notice, no findings were made against Herbert Smith Freehills LLP ("HSF London"), the parent firm of HSF Moscow. Throughout its investigation, OFSI notes that HSF London provided prompt and detailed disclosure relating to all breaches and was fully cooperative, which enabled OFSI to make a 50% reduction to the final penalty amount. Absent such disclosure, OFSI would have imposed a penalty of £930,000.
- 20 Mar 2025 (EU):
The Akin Summary document has now been posted for this action.
The European Commission (the "Commission") issued new Russia sanctions FAQs in respect of the "Infrastructure Transaction Ban" to offer further guidance on the scope, exemptions, and operation of the EU prohibition under Article 5ae of Council Regulation (EU) No. 833/2014 ("Regulation 833").
The OverRuled: China Trade Controls Resource Center has been updated with the following actions:
- 02 Apr 2025 (OFAC):
OFAC imposed sanctions on a network of Houthi financial facilitators and procurement operatives, pursuant to EO 13224. Specifically, it designated on the SDN List entities and individuals based in Russia, Hong Kong, and Türkiye, for having procured tens of millions of dollars of commodities from Russia, including weapons, dual-use materials, as well as stolen Ukrainian grain, for shipment to Houthi-controlled areas in Yemen.
The network of sanctioned parties worked in coordination with Sa'id al-Jamal, a senior Houthi financial official backed by Iran's Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF). OFAC previously designated Ansarallah (commonly known as the Houthis), Sa'id al-Jamal, and IRGC-QF on the SDN List, pursuant to EO 13224.
- 01 Apr 2025 (OFAC):
OFAC imposed sanctions on six entities and two individuals based in Iran, the United Arab Emirates, and the PRC, pursuant to EO 13382, by designating them on the SDN List. OFAC targeted these entities and individuals for procuring unmanned aerial vehicle ("UAV") components on behalf of Iran-based Qods Aviation Industries ("QAI")—a leading manufacturer for Iran's UAV program—and facilitating procurement for other entities in Iran's military-industrial complex, including Iran Aircraft Manufacturing Industrial Company ("HESA") and Shahid Bakeri Industrial Group ("SBIG").
QAI, HESA, and SBIG were previously designated by the United States, pursuant to EO 13382, respectively, in December 2013, September 2008, and July 2005.
- 31 Mar 2025 (OFAC):
The Department of State imposed sanctions on six Hong Kong officials, pursuant to EO 13936, for their engagement in actions or policies that threaten to further erode the autonomy of Hong Kong in contravention of China's commitments, and in connection with acts of transnational repression. These officials have been designated on OFAC's SDN List.
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