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Guy Soussan advises clients on various aspects of EU and French export control regulations, including controls and licensing regimes for both military and commercial products and technologies. His export practice covers compliance development and implementation, internal investigations, and enforcement matters, including voluntary disclosures. He also provides advice and assistance with EU economic sanctions targeting specific countries such as Iran, Libya, Syria, and most recently, Ukraine and Russia. His experience covers a wide range of industries, including manufacturing, energy, telecommunications, banking and insurance, petroleum and petro-chemicals, aerospace, and defense. He has conducted internal compliance audits, provided assistance on company compliance programs, and counseled clients on the application of the rules to specific transactions.

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On March 15, the Council of the EU proceeded to adopt the fourth package of sanctions against Russia over the continued military aggression of Ukraine. With these new sanctions, the EU seeks to address potential loopholes under the first three packages, such as by providing clarifications, to restrict certain derogations, and to expand the sanctions’ scope by targeting new sectors. In particular, the new sanctions target the energy sector, although significant carve-outs exist for coal, oil, and natural gas imports.

Following our review of the first, second and third sanctions package, we analyze below the latest restrictive measures which constitute the fourth package of sanctions.

For more information on how these developments could impact your organization, contact a member of Steptoe’s Economic Sanctions team in Brussels.

For additional resources can be found on Steptoe’s “Sanctions against Russia: Implications for Business and International Trade” page.

Continue Reading EU Adopts Fourth Package of Sanctions Against Russia

Since the adoption of the first sanctions package against Russia, the Council of the EU and the European Commission (“Commission”) have been working closely together to adopt increasingly severe sanctions to force President Putin back to the negotiating table in view of reaching a ceasefire. Coordination with allies has also been intense. Following our review of the first and second sanctions package, we analyze below the latest restrictive measures.

For more information on how these developments could impact your organization, contact a member of Steptoe’s Economic Sanctions team in Brussels.

For additional resources can be found on Steptoe’s “Sanctions against Russia: Implications for Business and International Trade” page.

Continue Reading Update: EU Adopts Additional Sanctions Against Russia and Belarus over the War in Ukraine

Following Russia’s invasion of Ukraine, the EU has adopted a much more severe sanctions package against Russia than the measures adopted on February 23, 2022 (see our previous previous blog post). The new measures provide for various restrictions, including additional targeted restrictions against specified individuals; expanded financial measures aiming at cutting Russia’s access to the EU capital markets; trade restrictions targeting the energy and aviation sectors and banning most exports of dual-use items, as well as certain semiconductors and cutting-edge technologies from the EU to Russia.

The key aspects of the new sanctions imposed by the EU are summarized below. Unless otherwise specified, references to Annexes in the below overview refer to Annexes to Council Regulation (EU) No 833/2014 (as amended or inserted by Council Regulation (EU) 2022/328 of February 25, 2022).

Continue Reading Update: EU Adopts Far-Reaching Sanctions following Russian Invasion of Ukraine

As the Ukraine Crisis continues to deteriorate following the Russian decision to recognise the Ukrainian regions of Donetsk and Luhansk as independent entities and officially deploying Russian troops, the EU has imposed its first set of sanctions. Also the US and the UK have imposed sanctions. The present blog post addresses the sanctions package that was adopted by the EU late on 23 February 2022. The EU, like other jurisdictions, is expected to issue additional sanctions shortly, and we will keep reporting on those.

The below Q&A provides you with all the information you need to gain a quick understanding of the EU’s Russia sanctions package of 23 February 2022.

Continue Reading Ukraine Crisis: EU imposes broad sanctions package on Russia

Significant diplomatic capital has been invested by the EU, the United States, the UK and NATO in developing policies to deter Russia from invading Ukraine. Sanctions have been the main focus of discussion. EU Member States agreed in Council Conclusions that potential sanctions will include “a wide array of sectoral and individual restrictive measures that would be adopted in coordination with partners”, and UK Prime Minister Johnson stated before parliament that the UK and its allies are considering “imposing coordinated and severe sanctions, heavier than anything we have done before against Russia”.

However, what exactly such statements mean remains unclear. Furthermore, government officials have explicitly refused to give any information when asked about the details, and those who have given information did so under the condition of anonymity. To help companies plan ahead in light of such uncertainty and to help assess the risk of exposure to EU/UK sanctions, we outline below what EU/UK sanctions may be adopted, and key indicators that may influence both the severity and timing of such sanctions.

Continue Reading Assessing Potential EU and UK Sanctions Against Russia

On 21 December 2021, the Court of Justice of the European Union (“CJEU”) delivered its judgment in Case C-124/20 Bank Melli Iran v Telekom Deutschland GmbH, which is the first case before the EU courts on the interpretation of Council Regulation (EC) No 2271/96 of 22 November 1996 protecting against the effects of the

On December 2, 2021, the United States, the EU, the UK, and Canada announced a new round of coordinated sanctions in response to their concerns regarding the Belarusian government’s continued undermining of democracy, its violations of human rights, and its alleged orchestration of irregular migration into the EU. The latest sanctions include blocking sanctions and asset freezes, as well as new restrictions on US persons dealing in Belarusian sovereign debt.

For more information on earlier US, UK, and Canadian sanctions related to Belarus, see our August 13, 2021, blog post and April 19, 2021, blog post.

Continue Reading Coordinated Sanctions Further Align Transatlantic Policies on Belarus

On September 9, 2021, the long-awaited recast of the EU Dual-Use Regulation (the Regulation) will enter into force. It provides for new rules on cyber-surveillance technology, the provision of technical assistance, as well as export restrictions for reasons of public security and human rights considerations. Additionally, the new Regulation provides for large project authorizations as well as two new EU General Export Authorizations.

Continue Reading Revised EU Dual-Use Regulation to Enter into Force

On July 20, 2021, the European Commission published its long-awaited legislative package titled “Anti-money laundering and countering the financing of terrorism” as announced in the Commission’s 2020 Action Plan for a comprehensive EU policy on preventing money laundering and terrorist financing (ML/TF).

As expected, the proposals seek to harmonize the application of more detailed anti-money

On June 21, 2021, the United States, the EU, the UK, and Canada announced coordinated sanctions following the forced and unlawful landing of a Ryanair flight in Minsk and the detention by Belarusian authorities of journalist Raman Pratasevich and Sofia Sapega, in May 2021. The sanctions include new EU sectoral-style sanctions against certain sectors of the Belarusian economy, as well as targeted financial sanctions against dozens of individuals and entities in connection with alleged human rights violations and the violent repression of civil society, democratic opposition, and journalists in Belarus.

The new sanctions follow the reactivation, on June 3, 2021, of longstanding sanctions against nine Belarussian companies and their subsidiaries by the US Treasury Department’s Office of Foreign Assets Control (OFAC), as discussed in our April 20, 2021 blog post.

Continue Reading Belarus Faces New EU, US, UK, and Canadian Sanctions After Ryanair Flight Diverted