This circular highlights recent key developments in the sanctions imposed against Russia by the UK, EU and US.
The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) recently issued 4 general licenses suspending certain sanctions in relation to transactions involving oil, gas, and gold in Venezuela.
Circular 08/23: EU Sanctions against Russia
04/07/2023
On 23 June 2023 the EU Council adopted the 11th package of economic sanctions against Russia to prevent their circumvention and further erode Russia’s revenues.
On 24 February 2023, the one year anniversary of Russia's invasion of Ukraine, the US Department of State and the US Department of Treasury's Office of Foreign Assets Control (OFAC) imposed sanctions on numerous additional individuals, entities and vessels that the US has determined are engaged in sanctions evasions.
On 25 February 2023, the EU adopted its 10th package of sanctions against Russia
Following significant engagement between the International Group and the Government of Turkey, an agreement has now been reached for such ships carrying crude oil cargoes and that will allow Members to continue voyages through Turkish controlled international straits and waters.
Circular 17/22: The Price Cap on Russian Oil
09/12/2022
The EU, G7 and Australia (the “Price Cap Coalition”) has recently introduced legislation and guidance effective 5 December 2022 intended to maintain the supply of Russian oil to world markets whilst at the same time reducing Russia’s earnings from its oil exports (the “Price Cap Scheme”).
EU updated FAQs on 19 Sept and 7 Oct 2022 to clarify transporting certain Russian goods to non-EU countries is not prohibited under Council Regulation (EU) 833/2014.
Circular 11/22: 8th EU Sanctions Package
11/10/2022
The EU adopted an eighth package of sanctions on 6 October 2022 in response to Russia’s continued military aggression against Ukraine.
On 19 September 2022 the EU further amended its FAQS clarifying the application of provisions relating to the carriage of certain cargoes from Russia
[AMENDED 22 JULY] On 21 July 2022 the European Union published a Maintenance and Alignment Package
UK Sanctions - New Trade Restrictions
27/07/2022
On 21 June 2022, the UK government imposed further trade restrictions against Russia under The Russia (Sanctions) (EU Exit) (Amendment) (No