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President Donald Trump issued an executive order (EO) earlier this month announcing sweeping “reciprocal” tariffs on imports from countries across the world. One country missing from the EO’s increased tariffs was Russia,...more
In its continuing response to Russia’s ongoing invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia and Belarus. This alert summarizes...more
On January 10, 2025, the United States announced (another) major sanctions package targeting Russia, potentially representing the Biden administration’s last and best effort to strengthen Ukraine’s negotiating position in...more
The Department of the Treasury's Office of Foreign Assets Control (“OFAC”) was active in October and November 2024. After issuing an Updated Price Cap Coalition Advisory for the Maritime Oil Industry and Related Sectors on...more
After a relatively quiet period, UK sanctions updates have picked up pace in recent weeks. We have seen the announcement of an enhanced partnership between US and UK sanctions agencies, updates to reporting requirements, the...more
As the Ukraine war progresses toward its third winter, Russian President Vladimir Putin finds himself besieged on numerous fronts. During the first 30 months of this conflict, Putin used his vast energy resources to hedge...more
In response to Russia’s invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia. This alert summarizes key economic sanctions imposed by...more
Contemporaneous with the European Union’s adoption of its 13th package of Russia sanctions, on February 23, 2024, the United States imposed sanctions against nearly 500 targets in continued response to Russia’s aggression...more
The Price Cap Coalition is an international partnership of the United States, the G7, the European Union, and Australia that was established in December 2022 to limit Russia’s ability to fund its war against Ukraine through...more
On June 23, 2023, the EU released its 11th package of sanctions on Russia. This package is designed to improve enforcement with new anti-circumvention rules, new trade restrictions, and new designations. The...more
New announcements and rules expand the scope of existing sanctions and export controls on Russia. This Client Alert is published in the context of ongoing developments and should be read in conjunction with the Latham’s...more
This update outlines the actions taken by U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) on Feb. 24, 2023, the one-year anniversary of the invasion of Ukraine by the Russian Federation (Russia)....more
The Biden Administration continues to place pressure on Russia, and on Feb. 24, 2023, marked the one-year anniversary of Russia's invasion of Ukraine with additional sanctions, export controls and tariffs. These new policies...more
Approximately one year ago, in the immediate wake of Russia’s full-scale invasion of Ukraine, the United States (U.S.), United Kingdom (UK), and European Union (EU) launched a global sanctions campaign against Russia that...more
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
This update addresses the full implementation of the price cap policy for crude oil and petroleum products of Russian origin by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). On Feb. 3, OFAC...more
As an update to an earlier Holland & Knight alert on the same topic, the U.S. Department of the Treasury Office of Foreign Asset Control (OFAC) has published another determination pursuant to Executive Order 14071 expanding...more
This update includes the U.S. Department of the Treasury’s Office of Foreign Assets Control’s (OFAC) recent actions regarding the Russian seaborne oil price cap policy aimed at maintaining the supply of Russian oil to the...more
OFAC’s guidance is intended to ease the burden on an otherwise difficult compliance problem. Companies have to act in good faith to avoid transacting business involving Russian crude oil that has been sold above the $60 per...more
The Biden Administration recognizes that the Russian Price-Cap Policy imposes serious burdens on U.S. energy companies and industries that provide ancillary services to the energy sector. It is even more complicated given...more
While OFAC is not always known for its clarity, the department is trying to make it easier for participants in global oil markets to comply with the Price-Cap Policy against Russian oil. This is not an easy task since there...more
The G-7, the European Union and Australia officially announced a price cap on Russian oil, which includes service and shipping restrictions on oil originating from the Russian Federation and trading above $60 per barrel. ...more