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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

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

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

UK Quarterly Review: Business Crime, Investigations, and Regulatory Enforcement - April 2022

As the world watches in horror as the Russian invasion of Ukraine continues to unfold, the UK, as well as its allies and partners, has introduced a number of sanctions and trade restrictions in response. In this Quarterly...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

Ukraine Crisis: UK Parliament Targets Opaque Property Ownership

In the wake of Russia’s invasion of Ukraine, the UK government has brought forward legislation that aims to crack down on foreign owners laundering dirty money through UK property and make it easier for law enforcement...more

UK Expands Russia Sanctions Regime in Anticipation of Ukraine Invasion

The UK government has widened the scope of its Russia sanctions regulations in anticipation of a Russian invasion of Ukraine. The amendments to the existing Russia sanctions regulations significantly broaden the definition of...more

2/15/2022  /  Amended Regulation , EU , Russia , Sanctions , UK , Ukraine

Congress Re-Enters the Nord Stream 2 Fight with Amendment to NDAA

In the latest turn of events in the seemingly never-ending political saga of the Nord Stream 2 pipeline, the U.S. House of Representatives (the “House”), via an amendment to the 2022 National Defense Authorization Act...more

OFAC 2020 Year In Review

In too many ways to count, 2020 was an extraordinary year. As we move into 2021 with optimism for an end to the pandemic and better days ahead, we understand that the activity last year of the U.S. Department of the...more

Trump Administration Broadens Sanctions On Russian Pipeline Projects (Again)

On October 20, 2020, the U.S. Department of State (“State”) broadened, yet again, the scope of sanctions applicable to Russian energy export pipeline projects, most notably the Nord Stream 2 pipeline, a nearly finished...more

Back In Business? OFAC Issues New General Licenses For Companies Doing Business With GAZ Group

Given the magnitude of current events gripping the country and the world, many otherwise noteworthy governmental actions are passing largely unnoticed. One such under-the-radar action occurred on July 22, 2020, when the U.S....more

Sanctions Followed: A New Round Of Sanctions Against China And Russia

As the new crown virus is spreading and there have been many demonstrations that "blacks are also fate," the US Congress has increased its work during the election year, threatening to strengthen sanctions against China and...more

Not So Fast…Aiming To Prevent Their Completion, The Trump Administration Paves Way For Expanded Sanctions On Russian Pipeline...

Earlier this week, on July 15, 2020, U.S. Secretary of State Mike Pompeo paved the way for enhanced sanctions on the Russian Nord Stream 2 and TurkStream projects by announcing that the Trump Administration is removing an...more

Sanctions Spree: New Round Of Sanctions Against China And Russia

Amid the COVID-19 pandemic and Black Lives Matter demonstrations, the U.S. Congress has stepped up its election year efforts by threatening heightened sanctions on China and Russia. The latest such bill, the Hong Kong...more

Congress Pulls the Trigger on Russia’s Nord Stream 2 and TurkStream Pipeline Projects

As it nears the end of the calendar and legislative year, Congress is preparing to take long-awaited action to kill Russia’s Nord Stream 2 and TurkStream natural gas pipeline projects – months before Nord Stream 2’s...more

TGIF? No, CBW: U.S. Government Imposes Narrow Financing Restrictions and Other Sanctions on Russia

The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has a well-earned reputation in the sanctions bar for ruining weekends. The agency responsible for implementing and enforcing U.S. economic sanctions has...more

For Russia, Sanctions Are Coming

Back in February, we told you about the Defending American Security from Kremlin Aggression Act, or “DASKA,” a bipartisan effort to impose new sanctions on Russia. Interest in action against the Kremlin has only increased...more

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