Russia/Ukraine Sanctions

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After weeks of going back and forth, the Council of the European Union (“Council”) was finally able to adopt the 10th package of sanctions against Russia in time to coincide with the first anniversary of Ukraine’s invasion on Friday, 24 February. Since a unanimous decision by the Member States is required in order to move forward with the sanctions, the adoption of the tenth package was delayed due to differences between certain countries over parts of the package.

The new set of measures include additional designations, trade and financial restrictions, reporting obligations, and further restrictions on Russian nationals. Most of the rules entered into force on 26 February 2023, the day following their publication in the Official Journal of the EU. The key measures described below can be found in the following documents:

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Continue Reading EU adopts 10th package of sanctions

On February 24, 2023, the US government announced a range of new export controls, sanctions, and tariffs to coincide with the first anniversary of Russia’s ongoing war against Ukraine. These actions by the US Department of Commerce, Bureau of Industry and Security (BIS), the US Department of the Treasury, Office of Foreign Assets Control (OFAC), the US Department of State, and the White House reflect the continued efforts of the US – in coordination with its allies – to impose costs on Russia for the war.

Each successive round of US export controls and sanctions presents new compliance challenges, against the backdrop of heightened enforcement risk resulting from aggressive, well-coordinated US government actions. US and non-US entities and individuals who engage in transactions related to Russia or Belarus should pay close attention to this complex and evolving regulatory framework. Additionally, entities and individuals exporting to Iran should take note of the expanded scope of the US Export Administration Regulations (EAR) under a new Iran Foreign Direct Product (FDP) Rule.…

Continue Reading US Imposes Additional Export Controls, Sanctions, and Tariffs targeting Russia, Belarus, and Iran On First Anniversary of Russia’s War Against Ukraine

In this blog post, we update our earlier post regarding OFAC’s determination and guidance on implementing the price cap policy for Russian crude oil (see link), by incorporating the recently released determinations regarding the price cap policy for Russian petroleum products and the updated guidance on implementing the price cap policy for Russian-origin crude oil and petroleum products.

On November 22, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) published a determination targeting Russian-origin crude oil pursuant to section 1(a)(ii) of Executive Order 14071 (EO 14071), and guidance on the implementation of the price cap policy for Russian-origin crude oil. These followed OFAC’s preliminary guidance released on September 9 (see Steptoe’s earlier blog post here).

Further, on February 3, 2023, OFAC published a determination targeting Russian-origin petroleum products pursuant to section 1(a)(ii) of EO 14071, and updated guidance on the implementation of the price cap policy for Russian-origin crude oil and petroleum products (the Updated Guidance).

The two determinations (the Determinations) set forth the categories of services relating to the maritime transport of Russian-origin crude oil and petroleum products (Covered Services) that US persons are prohibited from providing directly or indirectly to a person located in Russia, unless these items are purchased at or below relevant price cap. The Updated Guidance addresses issues relating to the implementation of the price cap policy for Russian-origin crude oil and petroleum products.…

Continue Reading [UPDATED] OFAC Publishes Determinations and Guidance on Implementing the Price Cap Policy for Russian Crude Oil and Petroleum Products

On February 7, 2023, the UK Department for International Trade (“DIT”) published an expanded version of its guidance on supplying professional and business services to a person connected with Russia (“DIT Guidance”), following a broadening of the types of services covered by the ban in December 2022.  The DIT Guidance sets out additional details regarding the services falling within the scope of these sanctions, enforcement, applicable exceptions, and the licence application process.  For more information on the ban on the supply of professional and business services, see our previous blog post (here).…

Continue Reading UK Expands Guidance on the Supply of Professional and Business Services to Persons Connected with Russia

On February 5, 2023, the UK ban imposed by Part 5, Chapter 4IA of The Russia (Sanctions) (EU Exit) Regulations 2019, as amended (“Russia Regulations”), on the maritime transportation of certain Russian oil products and related services came into effect.  Ahead of the measure coming into force, on February 4, 2023, HM Treasury’s Office of Financial Sanctions Implementation (“OFSI”) published an updated version of its guidance on the UK Maritime Services Prohibition and Oil Price Cap (“OFSI Guidance”), which outlines how the oil products price cap will be implemented, OFSI’s approach to enforcement, and the requirements on involved persons.  OFSI also issued two new General Licences that establish the level of the oil products price cap and establish a wind-down period with respect to certain Russian oil products.…

Continue Reading UK Oil Price Cap for Russian Refined Oil Products Comes into Effect

On December 15, 2022, The Russia (Sanctions) (EU Exit) (Amendment) (No. 17) Regulations 2022 (“Amendment 17”) were laid before parliament.  Amendment 17 revises existing restrictions on dealing with securities, money market instruments, loans and credit to prohibit new investments in Russia via third countries.  It also introduces a new prohibition on the provision of trust services to designated persons and persons connected with Russia, as well as expanding the existing ban on the provision of specified professional and business services to persons connected with Russia and making additions to the lists of items subject to existing trade sanctions.  Finally, Amendment 17 suspends the Bank of England’s duty under the Banking Act 2009 to make a decision in respect of a notification of third-country resolution action in respect of a designated person, or entities owned or controlled by such a person.  These measures came into effect on December 16, 2022.…

Continue Reading UK Introduces New Wave of Russia Financial and Trade Sanctions

On December 2, 2022, the G7, EU, and Australia (Price Cap Coalition) jointly agreed upon a cap on the price of seaborne Russian-origin crude oil at USD 60 per barrel as of December 5, 2022. The cap is subject to change based on the Coalition’s objectives and market fundamentals.

Upon reaching this consensus, the Treasury Department released a fact sheet on the same day providing additional details on the price cap policy, including its goals, how it works, and the compliance framework for the policy (the Fact Sheet). Most information has been previously discussed in the guidance released on November 22 (see our prior blog post at link). On December 5, the Treasury Department issued a Determination (the December Determination) pursuant to Executive Order 14071 and the prior Determination dated November 22 (the November Determination), to set the cap at USD 60 per barrel formally and to implement the policy.…

Continue Reading Price Cap Coalition Selects Level for Cap on Price of Seaborne Russian-Origin Crude Oil

On November 22, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) published a determination pursuant to Executive Order 14071 (EO 14071) (the Determination) and a guidance on the implementation of the price cap policy for Russian-origin crude oil (the Guidance). These followed OFAC’s preliminary guidance released on September 9 (see Steptoe’s earlier blog post here). The Determination sets forth the categories of services relating to the maritime transport of Russian-origin crude oil (Covered Services) that US persons are prohibited from providing directly or indirectly to a person located in Russia, unless the Russian crude oil is purchased at or below the price cap. The Guidance addresses issues relating to the implementation of the price cap policy for Russian-origin crude oil.…

Continue Reading OFAC Publishes Determination and Guidance on Implementing the Price Cap Policy for Russian Crude Oil

On November 21, 2022, the UK Department for Business, Energy and Industrial Strategy published guidance on the UK ban on Russian oil and oil products intended for entry into the UK (the “BEIS Guidance”) that was legislated for by the Russia (Sanctions) (EU Exit) (Amendment) (No. 14) Regulations 2022 and will come into effect on December 5, 2022.  Among other things, the BEIS Guidance explains how to determine the origin of oil or oil product imports to the UK and sets out UK sanctions authorities’ expectations with respect to compliance controls in relation to the ban.…

Continue Reading UK Government Publishes Guidance on the UK Ban on Oil and Oil Products

On November 14, 2022, HM Treasury’s Office of Financial Sanctions Implementation (“OFSI”) published detailed guidance on the recently published ban on the provision of maritime transportation of Russian oil and oil products and related services (“OFSI Guidance”).  The OFSI Guidance sets out additional details regarding how the oil price cap exception will operate as well as the attestation process and reporting obligations with which all parties involved in the maritime supply chain will need to comply.  The OFSI Guidance also addresses OFSI’s proposed approach to enforcement of the new ban.  For more information on the ban on the maritime transportation of Russian oil and oil products and related services, see our previous blog post (here).…

Continue Reading OFSI Publishes Guidance on the UK Maritime Services Prohibition and Oil Price Cap