The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 27 Mar 2025 (UK):
The Office of Financial Sanctions Implementation ("OFSI") extended the expiry date of General Licence INT/2023/2883496 (the "GL") relating to Lithuania Railways, issued pursuant to Regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019.
- 27 Mar 2025 (UK):
The Office of Financial Sanctions Implementation ("OFSI") amended General Licence INT/2022/1280976 (the "GL") concerning Regulatory Authorities – Prudential Supervision, Financial Stability, Protection of Consumers Or Integrity of The UK Financial System.
- 27 Mar 2025 (UK):
The Office of Financial Sanctions Implementation ("OFSI") updated the UK Financial Sanctions FAQs ("FAQs") to clarify whether a Relevant Institution may face enforcement action for breaching UK asset freeze measures if it creates and temporarily uses a suspense account to freeze funds owned, held, or controlled by a UK designated person.
- 24 Mar 2025 (UK):
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").
- 19 Mar 2025 (UK):
The Akin Summary document has now been posted for this action.
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.
- 18 Mar 2025 (Switzerland):
The Akin Summary document has now been posted for this action.
The Department of Economic Affairs, Education and Research ("EAER") removed seven individuals from its sanctions list.
- 14 Mar 2025 (UK):
The Akin Summary document has now been posted for this action.
The Office of Financial Sanctions Implementation ("OFSI") issued General Licence INT/2025/5886860 (the "GL") to allow UK Nationals (as defined in the GL) to purchase petrol from Gazprom Neft or a subsidiary (the "DP") in Kyrgyzstan or Tajikistan, provided that the petrol is for the UK National's personal vehicle.
- 14 Mar 2025 (EU):
The Akin Summary document has now been posted for this action.
The Council of the European Union adopted Council Decision (CFSP) 2025/528 amending Decision 2014/145/CFSP, and Council Implementing Regulation (EU) 2025/527, implementing Regulation (EU) No 269/2014 (together the "Legal Texts"), delisting four individuals and removing three deceased individuals from the EU's Russia sanctions regime.
- 12 Mar 2025 (EU):
The Akin Summary document has now been posted for this action.
The European Commission (the "Commission") updated its Russia sanctions FAQs relating to Oil Imports to clarify the permitted exceptions to the EU temporary storage prohibition pursuant to Article 3nb of Council Regulation (EU) No. 833/2014 ("Regulation 833").
- 12 Mar 2025 (UK):
The Akin Summary document has now been posted for this action.
The Office of Financial Sanctions Implementation ("OFSI") issued 13 new UK Financial Sanctions FAQs (FAQs 132 to 144 (inclusive)) to provide further clarification regarding the general reporting obligations of "relevant firms". As of May 14, 2025, this will include, amongst other "relevant firms" (as defined in Regulation 71 of the Russia (Sanctions) (EU Exit) Regulations 2019), art market participants ("AMPs") and high value dealers ("HVDs"), insolvency practitioners, and letting agents (each a "Relevant Firm" and together "Relevant Firms"). The definitions of AMPs, HVDs, insolvency practitioners, and letting agents are set out in Regulation 15 of the Sanctions (EU Exit) (Miscellaneous Amendments) (No. 2) Regulations 2024.
- 04 Mar 2025 (Switzerland):
The Akin Summary document has now been posted for this action.
The Department of Economic Affairs, Education and Research ("EAER") adopted further measures contained within the EU's 16th sanctions package targeting Russia of February 24, 2025. These measures include asset freeze sanctions against 48 individuals and 35 entities, restrictions against 74 vessels, SWIFT restrictions against 13 banks, tighter export controls against 53 additional entities, and a transaction ban against three banks.
The OverRuled: China Trade Controls Resource Center has been updated with the following actions:
- 24 Mar 2025 (China - Measures and Countermeasures):
The State Council issued the Provisions on the Implementation of the Anti-Foreign Sanctions Law (the "Provisions"), which elaborate on the scope of the punishments included in the countermeasures and refine coordination and implementation of the law by government departments.
The Anti-Foreign Sanctions Law was released in June 2021, in response to the discriminatory and restrictive measures adopted by foreign countries against Chinese citizens or entities.
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