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Enhanced Global Russian Sanctions and Export Controls to Counter Circumvention

On May 19, in response to Russia’s ongoing invasion of Ukraine, the United States, in coordination with allies and partners, announced new sanctions restrictions and export controls targeting Russia’s evasion networks,...more

The Emergence of a Global Russia Sanctions Enforcement Regime

The year since Russia’s invasion of Ukraine has been marked by the development of a multi-jurisdictional, multi-agency sanctions regime in the United States, the United Kingdom and the European Union. Although coordination...more

OFSI Issues Updated Guidance Relating to Assessments of due Diligence Conducted in Relation to the “Ownership and Control” Test,...

The Office of Financial Sanctions Implementation (OFSI) has updated its ‘enforcement and monetary penalties for breaches of financial sanctions’ guidance, which was last updated in June 2022. ...more

Global Jurisdictions Adopt New Price Cap on Russian Petroleum Products - New Guidance Creates Additional Compliance Expectations

Effective February 5, 2023, the Price Cap Coalition (the Coalition), consisting of the G7 nations, the European Union (EU) and Australia, set a price cap of $45 per barrel for “Discount to Crude” petroleum products of Russian...more

Global Jurisdictions Implement Russian Oil Ban and Price Cap Policy

A ban on services related to the maritime transport of Russian-origin crude oil sold above a pre-determined price cap of $60 per barrel began on December 5, 2022, with a similar price cap ban related to other Russian-origin...more

Sanctions Update: Global Jurisdictions Announce a Series of Wide-Ranging Russia Sanctions

We wanted to share an update on Russia sanctions developments in the United States, United Kingdom, and European Union that occurred between March 24 and April 8, 2022. Following new reports of atrocities committed by the...more

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