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Impact of Sanctions on English Contractual Performance – Case Update

In a recent decision, the English High Court has demonstrated its willingness to interpret contractual provisions broadly so as to enable performance in circumstances where the imposition of sanctions on a counterparty...more

Sanctions Year in Review 2022 – Part II: Russia

As Russia’s war in Ukraine passes the one-year mark, and the battles on the ground move forward with escalating levels of ferocity, governments around the world continue to coordinate and respond with increasingly severe...more

Managing Sanctions Risks Through Express Contract Provisions

The Singapore High Court recently ruled that a party to a Singapore law-governed contract was justified in relying on a sanctions clause in the contract to refuse payment to the counterparty in an effort to avoid breaching...more

Coalition Powers Impose Russian Oil Price Cap and Outline Implementation

As Russia’s war in Ukraine stretches into its tenth month, governments around the world continue to coordinate and respond with increasingly severe sanctions and export controls....more

UK Authorities Issue Red Alert on Russia Sanctions Evasion Typologies

On 13 July 2022, the National Economic Crime Centre, a multi-agency unit in the National Crime Agency (NCA), and the Office of Financial Sanctions Implementation, working in conjunction with law enforcement and financial...more

OFSI Fines UK Firm Located Overseas for UK Financial Sanctions Breach

The Office of Financial Sanctions Implementation (OFSI) imposed a £15,000 penalty on UAE-based and UK-registered entity, Tracerco Limited (Tracerco), for breaching UK sanctions when it purchased flights for an employee from...more

Global Sanctions on Russia Escalate in Response to Russia’s Continued Bloody Invasion of Ukraine

As Russia’s bloody invasion of Ukraine nears the end of its second month, with regular reports of human rights violations, possible chemical weapons attacks, and head of state musings regarding whether this campaign amounts...more

U.S., EU, and UK Sanctions on Russia Escalate in Response to Russia’s Continued Invasion of Ukraine

As Russia’s brutal invasion of Ukraine stretches on into its second month, the United States, European Union, United Kingdom, and other global allies have continued to pour additional funding and arms into Ukraine while...more

Risks Increase as UK Government Seeks to Introduce Strict Liability for Sanction Breaches

At a time when sanctions are very much in the spotlight, the UK government has proposed amendments to its sanctions regime in order to introduce a ‘strict civil liability’ test for sanctions breaches....more

United States, European Union, United Kingdom, and Other Nations Impose Sanctions in Response to Russia’s Brutal Invasion of...

After less than a week of a full-scale war between Russia and Ukraine, the post-Cold War global architecture appears irrevocably shattered, as Western nations line up to offer support and military and economic aid to Ukraine...more

Lessons Learned From OFAC’s 2021 Enforcement Actions So Far

As peak summer holiday season approaches, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) continues to remind the private sector of the importance of strict economic sanctions compliance. OFAC...more

Following U.S. Lead, UK Office Of Financial Sanctions Implementation Issues Maritime Guidance

Much of the world’s focus is on the COVID-19 pandemic, and rightfully so, but sanctions regulators also have their gazes fixed on another issue: the maritime industry. On May 14 2020, we saw the U.S. Departments of State and...more

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