The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 22 Nov 2024 (EU):
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 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").
- 21 Nov 2024 (OFAC):
The U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") added 16 individuals and 100 entities—including Gazprombank and many other Russian banks, plus over 40 registrars of securities—to the Specially Designated Nationals and Blocked Persons List (SDN List), and amended and deleted certain Non-SDN Menu-Based Sanctions List (NS-MBS List) entries related to Gazprombank.
Concurrent with these designations, OFAC also reissued two pre-existing Russia-related General Licenses ("GLs") to add Gazprombank-related authorizations (i.e. GL 53A "diplomatic missions of the Russian Federation" and 55C "authorizing certain services related to Sakhalin-2"), and issued GL 113 (wind down of transactions involving certain financial institutions blocked on November 21, 2024, including Gazprombank) and GL 114 (authorizing certain transactions related to debt or equity of, or derivative contracts involving, certain entities blocked on November 21, 2024, including Gazprombank).
Additionally, OFAC issued two new Russia-related FAQs (1201 and 1202) and amended three existing FAQs (976, 1096 and 1197).
Lastly, OFAC published a new Russia-related alert on sanctions risk for foreign financial institutions that join the Russian Financial Messaging System, a SWIFT-like system, for the transfer of financial messages.
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