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The U.S. and the UK moved quickly to prohibit the import of Russian LNG into their territories, but did not pass sanctions against the transportation of Russian LNG to other territories. Similarly, while the U.S. placed asset freeze sanctions on new Russian LNG projects such as the Arctic LNG 2 project, existing LNG infrastructure in Russia was not designated.
Continue Reading LNG sanctions on Russia – A fluid landscape

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…

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…

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,…

Following a 16-month diplomatic effort, on October 6, 2017, the U.S. government announced that it will terminate the vast majority of economic sanctions against Sudan. The revocation will be effective on October 12, 2017. Sanctions against South Sudan will remain in place as will sanctions in response to the situation in Darfur.

The EU position …

On the heels of United Nations Security Council Resolution 2375 released on September 11, 2017, President Trump issued a new executive order on September 21 (the EO) that greatly expands U.S. sanctions against North Korea, particularly so-called secondary sanctions, which apply to non-U.S. individuals and corporations. The EO establishes the following:

  • Broad new criteria for

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