The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 12 Sep 2024 (UK):
The Akin Summary document has now been posted for this action.
The UK Government published the Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 (the "Regulations"). The UK Government also announced the launch of the new Office of Trade Sanctions Implementation ("OTSI"), which will oversee the civil enforcement of trade sanctions when the Regulations come into effect on October 10, 2024.
- 11 Sep 2024 (UK):
The Akin Summary document has now been posted for this action.
The Foreign, Commonwealth and Development Office ("FCDO") specified ten vessels forming part of Russia's "shadow fleet" for the purposes of The Russia (Sanctions) (EU Exit) Regulations 2019.
- 10 Sep 2024 (OFAC):
The Akin Summary document has now been posted for this action.
The U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") and the U.S. Department of State designated four entities, four individuals, and nine vessels pursuant to Russia-related Executive Order ("E.O.") 14024, including Iran Air, which was concurrently designated by both OFAC and the Department of State, pursuant to Russia-related E.O. 14024 and Iran-related E.O. 13949, respectively. These designations target entities and individuals involved in Iran's delivery of weapons components and weapons systems, including unmanned aerial vehicles (UAVs) and close-range ballistic missiles (CRBMs), to Russia for use in its war against Ukraine.
- 10 Sep 2024 (UK):
The Akin Summary document has now been posted for this action.
The Office of Financial Sanctions Implementation ("OFSI"), together with the Foreign, Commonwealth and Development Office ("FCDO"), designated three entities and specified five cargo vessels under the Russia sanctions regime pursuant to The Russia (Sanctions) (EU Exit) Regulations 2019.
- 05 Sep 2024 (UK):
The Akin Summary document has now been posted for this action.
The UK published The Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2024 (the "Regulations"), amending The Russia (Sanctions) (EU Exit) Regulations 2019. The measures amend Regulation 54D concerning Legal Advisory Services, to make clear, amongst other amendments, that the provision of legal advisory services, which may otherwise be restricted by Regulation 54D of the Russia Regulations, are permitted on or in connection with compliance with global sanctions, Russian counter-sanctions, and global criminal law. In parallel, the General Trade Licence, Russia Sanctions – Legal Advisory Services, has been revoked on the basis that this is no longer required. The Regulations took effect on September 6, 2024.
- 05 Sep 2024 (OFAC):
The Akin Summary document has now been posted for this action.
The U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") designated two entities and two vessels pursuant to Russia-related Executive Order ("E.O.") 14024. These entities and vessels are associated with U.S.-designated Limited Liability Company Arctic LNG 2, one of Russia's key liquified natural gas projects.
Concurrently, OFAC issued General License ("GL") 108, which authorizes limited safety and environmental transactions involving entities and vessels blocked on September 5, 2024, through 12:01 a.m. Eastern Standard Time on November 6, 2024.
- 05 Sep 2024 (EU):
The Akin Summary document has now been posted for this action.
The European Commission updated its EU FAQs relating to the provision of services by clarifying whether EU persons must comply with the services prohibition under Article 5n of Council Regulation (EU) No. 833/2014 ("Regulation 833/2014"), even if those services are provided by virtue of being an employee of an EU parent company to a subsidiary in Russia.
- 05 Sep 2024 (EU):
The Akin Summary document has now been posted for this action.
The European Commission ("the Commission") updated its EU FAQs in respect of asset freezing measures and the prohibition on making funds and economic resources available to designated persons. The revised FAQs clarify the ownership threshold for establishing whether a non-designated entity is owned by two or more listed persons, as well as directing readers to the criteria for implementing firewalls set out within the Commission's guidance published on November 29, 2023.
- 04 Sep 2024 (OFAC):
The Akin Summary document has now been posted for this action.
The U.S. Department of the Treasury’s Office of Foreign Assets Control ("OFAC") designated ten individuals and two entities pursuant to Executive Order ("E.O.") 14024. These designations are part of a coordinated U.S. government response to Russia's malign influence efforts targeting the 2024 U.S. presidential election.
Concurrently, OFAC published an alert (the "Alert") to warn foreign jurisdictions and financial institutions about Russia's attempts to evade sanctions by opening new overseas branches and subsidiaries of Russian financial institutions.
OFAC also issued General License ("GL") 25E, which adds certain additional entities with which certain transactions related to telecommunications and internet-based communications are not authorized under the GL.
Lastly, OFAC amended FAQ 1040 to reflect the changes in GL 25E.
- 21 Aug 2024 (Switzerland):
The Akin Summary document has now been posted for this action.
Switzerland adopted measures of the EU's 14th sanctions package on Russian diamonds, as well as on deadlines for licenses on withdrawals of investments.
Please send an email to subscriptions@overruled.com if you would like information on how to subscribe to access additional detail about these and other sanctions- and export controls-related actions. If you are already a paid subscriber, please login to OverRuled for access to exclusive content, analysis, and historic search functionality.