The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 20 Mar 2025 (UK):
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.
- 19 Mar 2025 (UK):
The Office of Financial Sanctions Implementation ("OFSI") removed an individual, who was designated pursuant to the Russia (Sanctions) (EU Exit) Regulations 2019, from the Consolidated List.
The OverRuled: China Trade Controls Resource Center has been updated with the following actions:
- 20 Mar 2025 (OFAC):
The Department of State sanctioned a crude oil and petroleum products storage terminal in China, pursuant to EO 13846, for buying and storing Iranian crude oil from a sanctioned vessel.
Concurrently, OFAC designated a "teapot" oil refinery in China and its Chief Executive Officer for purchasing and refining hundreds of millions of dollars' worth of Iranian crude oil. In addition, OFAC imposed sanctions on 11 entities in Hong Kong, Liberia, the PRC, the Seychelles, Panama, and the British Virgin Islands, and identified eight vessels as blocked property, pursuant to EO 13902, for shipping millions of barrels of Iranian oil to China. OFAC's actions are being taken pursuant to EO 13902.
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