On May 23, 2025, the Office of Foreign Assets Control (OFAC) issued General License 25 (GL 25), authorizing transactions prohibited by the Syrian Sanctions Regulations, effectively lifting sanctions on Syria. This comes 10...more
5/30/2025
/ Banking Sector ,
Economic Sanctions ,
Energy Sector ,
EU ,
Foreign Policy ,
Investment ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Syria ,
Trump Administration ,
UK
On 2 April 2025, President Trump announced new tariffs on all imports into the United States. In this briefing, we summarise the key measures and the expected impact on global trade.
The new “reciprocal” tariffs -
The...more
4/4/2025
/ Canada ,
China ,
EU ,
Executive Orders ,
India ,
International Trade ,
Mexico ,
South Korea ,
Tariffs ,
Trade Relations ,
Trump Administration ,
UK ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies ,
Vietnam
The measure also harmonizes Russia sanctions rules with allies, and intensifies penalties against Iran -
The National Security Act, 2024 (Pub. L No 118-50) was enacted on April 24, 2024. In addition to the Act’s provisions...more
4/29/2024
/ China ,
EU ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Direct Product Rule ,
Iran ,
National Security ,
Regulatory Agenda ,
Regulatory Reform ,
Russia ,
Sanction Violations ,
Statute of Limitations ,
Trade Policy ,
UK
In recognition of the one-year anniversary of Russia’s invasion of Ukraine, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) and US Department of Commerce’s Bureau of Industry and Security (BIS)...more
3/6/2023
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Embargo ,
EU ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Financial Transactions ,
Foreign Policy ,
Foreign Relations ,
Foreign Trade Regulations ,
General Licenses ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Oil Prices ,
Petroleum ,
Russia ,
SDN List ,
Switzerland ,
Ukraine
On February 5, 2023, the G7 announced that the “price cap” on western-backed seaborne trades of Russian-origin petroleum products to third countries would be set at $45 per barrel ($45/bbl) for Discount to Crude petroleum...more
2/27/2023
/ EU ,
Exports ,
G7 ,
Goods or Services ,
Imports ,
Maritime Transport ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Oil Prices ,
Petroleum ,
Russia ,
Sanction Violations ,
Shipping ,
Suppliers ,
Supply Contracts ,
Ukraine
Oil price cap -
The oil price cap has been co-ordinated by the G7 in order to make EU, UK and US services (including (re)insurance) available to third country importers and exporters as long as the price paid for...more
12/12/2022
/ Asset Freeze ,
Belarus ,
Belarus Sanctions ,
Biden Administration ,
Crude Oil ,
Economic Sanctions ,
EU ,
Export Controls ,
Exports ,
G7 ,
General Licenses ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Oil Prices ,
Russia ,
SDN List ,
Switzerland ,
Third Country Entities (TCEs) ,
UK ,
Ukraine
Recently, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) has taken additional actions against Russia in response to its continued invasion of Ukraine. Specifically, OFAC:
..Issued guidance...more
10/31/2022
/ Asset Freeze ,
Belarus ,
Blocked Entities ,
Blocked Person ,
Economic Sanctions ,
EU ,
Export Controls ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Switzerland ,
Trade Restrictions ,
UK ,
Ukraine
As a follow up to our alert of September 7th regarding the G7 proposal to implement a price cap with respect to seaborne Russian-origin crude oil and petroleum products, the Office of Foreign Assets Control (OFAC)...more
9/13/2022
/ Crude Oil ,
Economic Sanctions ,
Embargo ,
EU ,
Maritime Transport ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Oil Prices ,
Recordkeeping Requirements ,
Russia ,
Safe Harbors ,
Shipping
On September 2, 2022, the G7 Finance Ministers issued a statement confirming their intention to implement a price cap with respect to Russian-origin crude oil and petroleum products in response to Russia’s continued invasion...more
9/8/2022
/ Crude Oil ,
Economic Sanctions ,
EU ,
G7 ,
Importers ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Pipelines ,
Pricing ,
Russia ,
Ukraine
Over the past few weeks, the US Department of the Treasury Office of Foreign Assets Control (OFAC) took additional actions in response to Russia’s continued invasion of Ukraine:
..Removed Kazakh subsidiary of Alfa Bank,...more
The US continues to ramp up sanctions pressure on Russia, now emphasizing Russian efforts to evade US export controls and obligations of financial institutions to police Russian efforts at sanctions and export controls...more
7/6/2022
/ Asset Freeze ,
Belarus ,
Belarus Sanctions ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Entity List ,
EU ,
Export Controls ,
Exports ,
FinCEN ,
Foreign Relations ,
General Licenses ,
Military Conflict ,
Oil & Gas ,
Russia ,
Switzerland ,
Trade Restrictions ,
UK ,
Ukraine
During the past week, the US continued to strengthen its sanctions against Russia as Russia continued its invasion of Ukraine.
..BIS issued a final rule clarifying which luxury goods are subject to the ban on exports to...more
3/28/2022
/ Asset Freeze ,
Belarus ,
Economic Sanctions ,
EU ,
Export Controls ,
Exports ,
General Licenses ,
Imports ,
Russia ,
Trade Restrictions ,
UK ,
Ukraine
Following the invasion of Ukraine by Russia, the UK, EU and US have all responded by announcing significant sanctions in respect of Russia and Belarus.
The sanctions landscape has been changing at a fast pace and further...more
3/23/2022
/ Asset Freeze ,
Belarus ,
Blocked Entities ,
Blocked Person ,
Economic Sanctions ,
Entity List ,
EU ,
Export Controls ,
Foreign Relations ,
General Licenses ,
Russia ,
SDN List ,
Switzerland ,
UK ,
Ukraine
This briefing is intended to provide an update on two recent developments under the US sanctions regime.
..The first one is the introduction of US sanctions related to the Nord Stream 2 pipeline project, which threaten to...more
1/30/2020
/ Administrative Procedure Act ,
Blocking Sanctions ,
Civil Monetary Penalty ,
Construction Industry ,
Contract Formation ,
Defense Sector ,
Economic Sanctions ,
Energy Projects ,
Energy Sector ,
Enforcement Actions ,
EU ,
Exxon Mobil ,
Fair Notice ,
Federal Budget ,
Foreign Policy ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Pipelines ,
Prohibited Transactions ,
Russia ,
SDN List ,
Summary Judgment ,
Vessels
As of November 5, 2018, US secondary sanctions against Iran are back in force, and more than 700 Iranian individuals and entities have been re-added or newly added to the US Specially Designated Nationals and Blocked Persons...more