Hughes Hubbard’s “Sanctions in a Snap” is intended to provide a clear and concise summary of recent and important developments from the European Union (EU) and its member states. We hope you find it helpful in assessing EU economic sanctions and export controls risks against the current EU regulatory framework and enforcement priorities.
Highlights from October 2025 include the EU’s adoption of its 19th sanctions package against Russia, updated guidance on (i) dual-use and advanced technology export controls, (ii) an import ban on refined oil originating from Russian crude, and select case law and enforcement actions, including the European Court of Justice’s (ECJ) confirmation of reporting obligations for individuals subject to asset-freezing measures, France’s detention of crew members aboard a Russian-linked oil tanker suspected of sanctions evasion, and Denmark’s issuance of its first fine under the Russia sanctions regime for an attempted export of dual-use goods.
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