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EU Aims for Harmonized Sanctions Enforcement With Defined Criminal Offences and Penalties

European Union member states have until 20 May 2025 to transpose into their national legislation EU Directive (EU) 2024/1226 (the Directive), which establishes minimum rules on the definition of criminal offences and...more

EU Updates Sanctions Best Practices, Clarifying Ownership Threshold for Asset Freeze Restrictions

The Council of the European Union (Council) has updated its EU Best Practices for the Effective Implementation of Restrictive Measures. Published on 3 July 2024, the new version clarifies the threshold for the ownership test...more

EU’s 14th Sanctions Package: Compliance Obligations Expand and Exits Are Facilitated

On 24 June 2024, the European Union (EU) adopted its 14th sanctions package directed against Russia, imposing an asset freeze against an additional 116 individuals and entities and expanding sectoral sanctions targeting key...more

EU Expands Restrictive Measures in 13th Russian Sanctions Package and Publishes Guidance

On 23 February 2024, the European Union (EU) adopted a 13th package of sanctions against Russia, imposing asset freezes on additional individuals and entities, expanding existing sectoral sanctions and further limiting...more

France Strengthens Foreign Investment Controls, Expands Jurisdiction to ‘Commercial Establishments’ Registered in France |...

On 28 December 2023, the French government adopted decree number 2023-1293 (Decree), together with an administrative order of the same date (Order), that expanded the scope of covered investments and covered activities under...more

EU Further Strengthens Restrictive Measures Against Russia in 12th Package of Sanctions

On 18 December 2023, the European Union adopted a 12th package of sanctions against Russia. The sanctions impose an asset freeze on more than 140 individuals and entities pursuant to Council Regulation (EU) 269/2014...more

EU Commission Issues Guidance for EU Companies on Enhanced Due Diligence To Prevent Sanctions Circumvention

On 7 September 2023, the European Commission (Commission) published a guidance note (the Guidance) for EU businesses on the circumvention of sanctions. The Guidance outlines the essential components for a company’s compliance...more

EU Increases Russia-Related Restrictions and Expands Anti-Circumvention Measures in 11th Package of Sanctions

The new sanctions focus particularly on preventing the circumvention of EU sanctions rules through the jurisdictions of third countries. The EU has published lists of dual-use goods and advanced technology items (so-called...more

EU Adopts 10th Set of Sanctions Against Russia and Strengthens Enforcement and Anti-Circumvention Measures

The European Union (EU)’s tenth package of sanctions against Russia, adopted 25 February 2023, imposed an asset freeze against 121 individuals and entities and expanded the scope of sectoral sanctions....more

France Extends Interim Rule on Foreign Direct Investments

On 23 December 2022, the French government issued decree number 2022-1622, which extended to 31 December 2023 the interim rule, in effect for two years now, that lowered the threshold that triggers foreign investment review...more

Latest EU Russian Sanctions Expand Sector Restrictions and Add Designated Individuals and Entities

On 16 December 2022, the European Union (EU) adopted a ninth package of sanctions against Russia. These impose an asset freeze on almost 200 additional individuals and entities pursuant to Council Regulation No. 269/20141...more

EU and UK Price Cap on Russian Crude Oil

On 5 December 2022 the $60 per barrel price cap on Russian crude oil announced by the G-7 finance ministers in September 2022 came into effect in the United States, European Union and United Kingdom. The price cap is...more

France Issues Guidelines on Foreign Investment Control Regime

On September 8, 2022, the French Ministry of the Economy’s (MOE) General Treasury Department published its first set of guidelines on French foreign direct investment (FDI) control....more

US, UK and EU Expand and Amend Russian Sanctions, Responding to Purported Annexations of Ukrainian Regions

In light of the recent referendums and purported annexation by Russia of four territories of Ukraine on September 30, 2022, the United States, United Kingdom and European Union have expanded measures and provided additional...more

EU and UK Adopt Further Sanctions and Export Controls Targeting Russia

In recent months, the European Union and United Kingdom have adopted additional measures targeting key elements of the Russian economy in response to the invasion of Ukraine. Specifically, the EU and UK continue to expand the...more

FinCEN and Federal Reserve Propose To Significantly Lower Threshold for International Funds Transfers Under Recordkeeping and...

On October 27, 2020, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) and the Board of Governors of the Federal Reserve System (Federal Reserve, together with FinCEN, “the Agencies”)...more

France Issues Interim Rules on Certain Foreign Investments in Response to COVID-19

On July 23, 2020, the French government issued decree nº 2020-892 of July 22, 2020 (the Decree), and a ministerial order of the same date (together, the Interim Rules), which lowered the applicable threshold that triggers...more

France Moves To Protect Strategic Assets Amid COVID-19 Pandemic

On April 29, 2020, the French Minister of the Economy (the Minister) announced that French foreign investment rules will be adopted with the policy goal of protecting French strategic assets in the context of the COVID-19...more

France Completes Major Foreign Investment Reform

On December 31, 2019, the French government issued decree nº 2019-1590 (the 2019 Decree), together with an administrative order of the same date (the Order), that comprehensively reshaped French foreign investment rules (as...more

New Executive Order Authorizes the Imposition of Sanctions to Counter Corruption in Venezuela

On November 1, 2018, President Donald Trump issued Executive Order 13850 (E.O. 13850), which broadly targets corrupt practices in Venezuela and builds on several recent rounds of U.S. sanctions against the Venezuelan...more

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