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FCPA Compliance and Ethics Report-Episode 153-Doing Compliance in an Economic Downturn
What are they and what do they do? Over the past twelve months, lenders in the maritime transportation industry have increasingly required provisions in loan agreements (the “Russian Oil Provisions”) whereby the borrowers...more
The UK’s latest sanctions affect multiple areas and actors, including Turkish, Chinese, and Dubai-based entities alleged to support Russian military activities. This Client Alert is published in the context of ongoing...more
Since Israel killed Iran Revolutionary Guard Commander General Mohammed Reza Zahedi and six others in Damascus, Syria on April 2, Iran has sworn that it will retaliate harshly against Israel. Israeli soldiers have had their...more
The recent rise in royalty class action lawsuits brought by the plaintiffs’ bar, that generally coincides with the ebb in crude oil prices, is a growing risk for oil and gas companies. Class action certifications in royalty...more
The Energy Act 2023 (the “Act”) (in force as from 26 October 2023) amends model clauses contained in exploration and production licences to introduce requirements for consent to be obtained from the North Sea Transition...more
2023 was another significant year for UK sanctions. The UK government has continued to implement new sanctions against Russia in response to its illegal war in Ukraine, including through new designations, broadened financial...more
In this weekly update, we summarise the most notable updates in the UK sanctions world. ...more
1. Russia Sanctions - UK Government increases the deadline for providing certain information in relation to the Maritime Services Ban and Oil Price Cap Exception: On March 8, 2024, the UK Government increased the deadline...more
El Gobierno Nacional de Colombia modificó mediante el Decreto 0242 de 2024 las tarifas de retención y autorretención aplicables a las empresas del sector minero y de hidrocarburos. Estas modificaciones fueron realizadas con...more
On February 1, 2024, the G7+ Coalition (consisting of the G7, the European Union, and Australia) published an Oil Price Cap (OPC) Compliance and Enforcement Alert (the “Alert”), identifying notable OPC evasion methods and...more
On February 8, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced the imposition of sanctions against a network of foreign entities and a vessel involved in an asserted price cap...more
On February 1, 2024 the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a comprehensive "Oil Price Cap Compliance and Enforcement Alert" (the “Alert”) to bolster enforcement of the Russian...more
The Price Cap Coalition is an international partnership of the United States, the G7, the European Union, and Australia that was established in December 2022 to limit Russia’s ability to fund its war against Ukraine through...more
In light of the ongoing Russian invasion of Ukraine, the UK and EU, in close collaboration with their G7 partners, have continued to exert economic pressure on Russia through an array of sanctions. In this bulletin, we...more
The court has looked at a “hindrance” on paying a debt in the context of a force majeure clause and whether a sanctions clause or the general law of sanctions excused payment. Litasco, a Swiss company wholly owned by a...more
With Russia’s invasion of Ukraine nearing the end of its second year, the United Kingdom has continued to introduce sanctions measures against Russia, with the latest round announced on 14 December 2023....more
The pessimist complains about the wind; the optimist expects it to change; the realist adjusts the sails. – William Arthur Ward The U.S. maritime industry is much like a great ship: It is subject to unforeseen forces, and it...more
Throughout December, the United States, European Union, and United Kingdom adopted a series of new sanctions packages against Russia that are expansive and multilayered and pose additional compliance challenges. The new...more
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has renewed its commitment to squeezing Russia’s oil proceeds, releasing updated guidance with enhanced attestation and record-keeping requirements...more
EU’s 12th Sanctions Package - On 19 December 2023, the Council of the European Union (EU) together with the Commission published its 12th round of sanctions....more
On December 1, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets control (OFAC) announced the imposition of sanctions on three entities and identified as blocked property three vessels that used Price Cap...more
U.S. authorities have been active in November 2023, reinforcing and expanding sanctions targeting Russia's war effort in Ukraine. Multiple agencies added sanctions targeting entities involved in Russia's military supply...more
The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) on Oct. 12, 2023, designated two tank vessels and their registered owners as Specially Designated Nationals (SDNs) for allegedly transporting...more
On October 12, 2023, the Department of the Treasury's Office of Foreign Assets Control (“OFAC”) published a Maritime Oil Industry Advisory (“Advisory”)—together with the so-called Price Cap Coalition (“Coalition”), consisting...more