The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 29 Nov 2024 (Switzerland):
The State Secretariat for Economic Affairs ("SECO") published a form that needs to be used for certain requests for the release of frozen funds and/or economic resources.
- 25 Nov 2024 (UK):
The Akin Summary document has now been posted for this action.
The Office of Financial Sanctions Implementation ("OFSI") designated ALFASTRAKHOVANIE PLC and VSK, pursuant to the Russia (Sanctions) (EU Exit) Regulations 2019.
- 25 Nov 2024 (UK):
The Akin Summary document has now been posted for this action.
The Foreign, Commonwealth and Development Office ("FCDO") specified 30 vessels under the UK's Russia sanctions regime, pursuant to The Russia (Sanctions) (EU Exit) Regulations 2019.
- 22 Nov 2024 (EU):
The Akin Summary document has now been posted for this action.
The European Commission (the "Commission") issued new Russia sanctions FAQs relating to the "Best Efforts" obligation, pursuant to Article 8a of Council Regulation (EU) No. 833/2014 ("Regulation 833"). The new FAQs seek to clarify, inter alia:
- the concepts of "best efforts" and "undermining" under Article 8a;
- the scope of Article 8a;
- how Article 8a should be applied when doing so is prevented by the laws of a third country;
- how EU operators can sufficiently demonstrate compliance with Article 8a; and
- the obligations of EU operators in respect of non-EU entities that produce or supply goods subject to EU export/import bans.
- 21 Nov 2024 (UK):
The Akin Summary document has now been posted for this action.
The Office of Financial Sanctions Implementation ("OFSI") issued an advisory (the "Advisory") regarding the evasion of the oil price cap (the "Price Cap") through fabricated and falsified certificates of origin ("CO").
- 18 Nov 2024 (UK):
The Akin Summary document has now been posted for this action.
The Foreign, Commonwealth and Development Office specified the Russian cargo ship, PORT OLYA-3 (IMO: 9481910), in response to its role of transporting weapons, including ballistic missiles, from Iran to Russia for use on the battlefield in Ukraine.
- 14 Nov 2024 (UK):
The Akin Summary document has now been posted for this action.
The UK Government passed the Sanctions (EU Exit) (Miscellaneous Amendments) (No. 2.) Regulations 2024 (the "Amendment Regulations"), which makes key amendments to the Russia (Sanctions) (EU Exit) Regulations 2019 (the "UK Russia Regulations"). Most of the amendments will come into force on December 5, 2024; the extension of financial sanctions reporting obligations to new sectors will come into force on May 14, 2025.
- 14 Nov 2024 (UK):
The Akin Summary document has now been posted for this action.
The Office of Financial Sanctions Implementation ("OFSI") published new UK Financial Sanctions FAQs (the "FAQs") (FAQs 125-131) to reflect the new required payments exception, introduced by the Sanctions (EU Exit) (Miscellaneous Amendments) (No.2) Regulations 2024 (the "Amendment Regulations"). The required payments exception will come into force on December 5, 2024.
- 11 Nov 2024 (UK):
The Akin Summary document has now been posted for this action.
The Office of Financial Sanctions Implementation ("OFSI") updated the UK"s Financial Sanctions FAQs ("FAQs") to clarify whether equities that are transferred from the Russian National Settlement Depository ("NSD") to local registrars, pursuant to Presidential Decree 840, should continue to be treated as frozen assets by relevant institutions.
- 07 Nov 2024 (UK):
The Akin Summary document has now been posted for this action.
The Office of Financial Sanctions Implementation ("OFSI") extended the expiry date of General Licence INT/2022/1710676 (the "GL") in respect of the continuation of business with Evraz Plc's North American subsidiaries.
The OverRuled: China Trade Controls Resource Center has been updated with the following actions:
- 03 Dec 2024 (China - Measures and Countermeasures):
The Ministry of Commerce issued certain restrictions on the export control of dual-use items to the United States, in response to the United States' new export controls on China's chip industry.
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