On May 23, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Syria General License (GL) 25 to provide immediate sanctions relief for Syria in line with President Trump’s May 13, 2025...more
On Thursday, the European Commission opened a public consultation on a proposed list of U.S. imports that could face European Union (EU) countermeasures if current negotiations between the EU and the U.S. fail to reach a fair...more
On March 20, 2025, the U.K.’s Office of Financial Sanctions Implementation (OFSI) announced that, in accordance with section 146 of the Policing and Crime Act 2017 (PACA), a monetary penalty of £465,000 had been imposed...more
3/27/2025
/ Compliance ,
Due Diligence ,
Economic Sanctions ,
Enforcement Actions ,
Office of Financial Sanctions Implementation (OFSI) ,
Penalties ,
Regulatory Requirements ,
Reporting Requirements ,
Risk Management ,
Russia ,
UK
On 11 March 2025, the Department for Business and Trade through the Export Control Joint Unit (ECJU), issued a notice to exporters providing advance notice of updates to the UK Strategic Export Control Lists, which are...more
Background - The war in Ukraine has taken a new diplomatic turn in recent weeks. Having historically aligned with the European Union (EU) and United Kingdom (UK) on its condemnation of Russia’s war in Ukraine, and the need...more
3/17/2025
/ Asset Freeze ,
Economic Sanctions ,
EU ,
Foreign Policy ,
Foreign Relations ,
International Trade ,
National Security ,
NATO ,
Russia ,
UK ,
Ukraine ,
United States
The European Union (EU) had said repeatedly that it will retaliate in case of U.S. tariffs, which the EU sees as unjustified. The EU preferred (and attempted) a negotiated solution but moved swiftly to retaliation once the...more
3/14/2025
/ Aluminum Sales ,
Enforcement Actions ,
EU ,
European Commission ,
Imports ,
International Trade ,
Regulatory Agenda ,
Regulatory Requirements ,
Section 232 ,
Steel Industry ,
Supply Chain ,
Tariffs ,
Trade Policy ,
Trade Relations
Scottish chip firm loses temporary injunction application for relief while divestment decision is challenged by judicial review, following the UK issuing its third Annual Report on the NSIA. The UK High Court of Justice has...more
As we enter 2025 with a new president in the White House and Republicans in control of both the House and the Senate, we can look forward to a significant shift in the landscape for oil & gas transactions. The second Trump...more
1/16/2025
/ Biden Administration ,
Clean Energy ,
Climate Change ,
Energy Policy ,
Energy Sector ,
Environmental Justice ,
Environmental Policies ,
Federal Trade Commission (FTC) ,
FERC ,
Fossil Fuel ,
Inflation Reduction Act (IRA) ,
Legislative Agendas ,
Natural Gas ,
Oil & Gas ,
Private Equity ,
Renewable Energy ,
Tariffs ,
Trump Administration
In 2021, the European Union (EU) updated the EU Dual-Use Regulation, setting unified standards for EU member states to control exports of dual-use items. A key addition in Regulation (EU) 2021/821 is Article 5’s “catch-all...more
12/2/2024
/ Cybersecurity ,
Dual Use Goods ,
Due Diligence ,
EU ,
Exporters ,
Exports ,
Misuse of Information ,
Regulatory Agenda ,
Software ,
Surveillance ,
Telecommunications ,
Transparency
On 22 November 2024, the European Commission (the “Commission”) issued new frequently asked questions (FAQs) regarding the interpretation of the “Best Efforts” obligation in Article 8a of Council Regulation (EU) No. 833/2014...more
Key Takeaways - On 12 September 2024, the UK government published the Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 (the “Regulations”), which will come into force on 10 October 2024. The...more
Key Takeaways - On 3 July 2024, the Council of the European Union (the “EU Council”) published its revised Update of the EU Best Practices for the effective implementation of restrictive measures (“Best Practices”).This...more
7/23/2024
/ Best Practices ,
Buyback Programs ,
Economic Sanctions ,
EU ,
Limited Liability Company (LLC) ,
Majority Shareholders ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Shell Corporations ,
Trusts ,
UK
Key Points - Following our Alert last month addressing the United Kingdom Government’s intentions to improve the workings of the National Security and Investment Act 2021 (NSIA), the U.K. Government has now published two new...more
5/28/2024
/ Acquisitions ,
Foreign Direct Investment ,
Foreign Investment ,
Insolvency ,
Intellectual Property Protection ,
Investment ,
National Security ,
Restructuring ,
Risk Assessment ,
Supply Chain ,
UK
Key Points - On Thursday, the UK government announced its intention to improve the workings of the NSIA, “ in these dangerous and uncertain times [when] our economy is increasingly the target for our adversaries.” In November...more
On 11 March 2024, the UK expanded its export control regime to include new controls on specific emerging technologies, such as quantum computing, semiconductor technologies and additive manufacturing, under The Export Control...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
12/27/2023
/ Asset Freeze ,
Banking Sector ,
Cryptocurrency ,
Economic Sanctions ,
EU ,
European Economic Area (EEA) ,
Export Controls ,
Fund Transfers ,
G7 ,
Imports ,
Information Sharing ,
Insurance Industry ,
Licensing Rights ,
Metals ,
Oil Prices ,
Pipelines ,
Propane ,
Reporting Requirements ,
Russia ,
SDN List ,
Software ,
Technology Sector ,
Telecommunications ,
Trade Restrictions ,
Transparency ,
UK
The UK announced that it will require importers to pay a carbon levy on certain goods imported from countries with a lower or no carbon price.
Covered goods under the UK’s carbon border adjustment mechanism (CBAM) likely...more
Key Takeaways -
On 17 November 2023, the Foreign, Commonwealth & Development Office (FCDO) and Office of Financial Sanctions Implementation (OFSI) published new guidance on Ownership and Control: Public Officials and...more
On 23 June 2023, the European Union (EU) adopted a new package of economic sanctions against Russia. In addition to other measures, the 11th sanctions package has specifically widened prior financial restrictions applicable...more
On 28 March 2023, the UK Office of Financial Sanctions Implementation of HM Treasury (“OFSI”) issued the “Bond amendments and restructurings for non-Designated Persons” general licence (General Licence - INT/2023/2824812)...more
The last 12 months have seen dramatic falls in fintech and payments valuations, but with the payments sector now a core part of the financial services ecosystem, strategic imperatives will continue to drive deals despite...more
Introduction -
In 2022, the United States, European Union (EU) and United Kingdom, along with a significant number of other partners and allies, imposed an unprecedented number of economic, financial and trade sanctions...more
Since Russia’s invasion of Ukraine in February 2022, we have seen an extraordinary range of sanctions and export controls restrictions introduced by tens of countries worldwide. The current sanctions imposed on Russia by the...more
The United Kingdom just issued a new statutory instrument, effective immediately, which extends the authority to designate persons and entities under the U.K. sanctions against Russia.
Previously, the U.K. government...more
Key Points -
The United States, European Union, United Kingdom and other U.S. allies are currently considering a range of severe economic measures against Russia to impose in the event of a Russian military incursion into...more
1/31/2022
/ Export Administration Regulations (EAR) ,
Export Controls ,
Financial Institutions ,
Foreign Policy ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Pipelines ,
Russia ,
Sanctions ,
SDN List ,
Ukraine