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On June 3, 2022, the European Union Council adopted a sixth package of sanctions against Russia, which will phase-out the import of Russian oil and petroleum products over the next six to eight months.  This particular round of sanctions will not restrict the import of gas, but official guidance warns that “nothing is off the table”.Continue Reading EU sixth package of sanctions against Russia

The English Court of Appeal handed down judgment in the case of Lamesa Investments Limited v. Cynergy Bank Limited [2020] EWCA Civ 821 on 30 June 2020.

The Court of Appeal upheld the High Court’s decision that U.S. sanctions targeting Lamesa Investments Limited’s (LIL) ultimate owner justified Cynergy Bank Limited’s (CBL) withholding of interest payments

In response to the evolving challenges facing the shipping industry in 2019, BIMCO has released new standard sanctions clauses for time and voyage charter parties. The release attempts to respond, in particular, to the United States’ more aggressive sanctions regimes for Iran and Venezuela, which have strained the previous BIMCO language. BIMCO states that the

On 14 January 2020, the UK, France and Germany (the “E3”) triggered the dispute resolution mechanism under the JCPOA by referring assertions of Iranian non-compliance to the Joint Commission.

The triggering of the dispute resolution mechanism could (but not necessarily will) lead to the re-imposition of UN and EU sanctions on Iran, though the statement

On Monday, March 25, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) updated the advisory document it published in November 2018 on the risks for parties involved in petroleum shipments to Syria. The update adds to the list of deceptive shipping practices used to obfuscate the destination of petroleum bound

On 8 May 2018, President Trump announced that the United States would withdraw from the Joint Comprehensive Plan of Action (JCPOA). In conjunction with that announcement, the President issued a National Security Presidential Memorandum (NSPM) directing the re-imposition of certain secondary sanctions, being those that apply to non-U.S. persons even where there is no U.S. nexus (e.g. no U.S. persons, no U.S.-origin goods, or U.S. dollar payments). As discussed in our earlier blog post, the first batch of sanctions was reimposed on 6 August  and the second batch will become effective 5 November.
Continue Reading IRAN SANCTIONS – UPDATE

As readers will be aware, following President Trump’s announcement on 8 May 2018, the USA has indicated its withdrawal from the Iran nuclear deal – the JCPOA – and that it will be reimposing secondary sanctions on Iran, being those which affect non-U.S. persons. The first tranche of secondary sanctions took effect in early August,

In the early hours of Tuesday, 7 August 2018, and as foreshadowed by President Trump’s announcement on 8 May 2018, the United States reimposed certain secondary sanctions on Iran, being those which apply to non-U.S. persons. The imposition of these sanctions follows the conclusion of a 90-day wind-down period and, as mentioned in our previous blog post, will impact (among other things) trade in graphite, raw or semi-finished metals and the Iranian automotive sector. Importantly, the new Iran sanctions permit the U.S. government to impose sanctions on non-U.S. persons who provide significant support to those acting in violation of the sanctions. Note that a second wind-down period expires in early November, at which time further secondary sanctions will be reimposed, affecting, among other things, shipping, the petroleum and petrochemical industry, and insurance.
Continue Reading IRAN SANCTIONS: UNITED STATES REIMPOSES SANCTIONS AND THE EU RESPONDS

On 8 May 2018, President Trump announced that the United States would withdraw from the Joint Comprehensive Plan of Action (“JCPOA”). In conjunction with that announcement, the President issued a National Security Presidential Memorandum (“NSPM”) directing the re-imposition of certain secondary sanctions, being those that apply to non-US persons even where there is no US nexus. Depending on the economic sector targeted, the particular sanction will be imposed either 90 or 180 days after the President’s announcement (6 August and 5 November, respectively).
Continue Reading Iran Sanctions – August Deadline

On 8 May 2018, President Trump announced his decision to withdraw the United States from the Joint Comprehensive Plan of Action (JCPOA) and to reimpose on Iran a multitude of sanctions that were lifted in January 2016 under the JCPOA.

This means a significant change to non-U.S. companies’ ability to trade Iran, and has particular