In the last week, President Trump has threatened “secondary” tariffs in three distinct scenarios. While this is the first time that the Administration has used the term “secondary” tariffs, the terminology is likely intended to mirror that used in the sanctions context and, as with “secondary” sanctions, appears designed to be another mechanism by which
Firms at Risk of Monetary Penalty for Breaches of UK Financial Sanctions Imposed on Russia
The UK’s Office of Financial Sanctions Implementation (“OFSI”) has imposed a monetary penalty of £465,000 against a multinational law firm’s Russian office (the “Russian Office”) for breaching UK financial sanctions against Russia following its invasion of Ukraine in February 2022. This is the first time OFSI has enforced against a law
The Maximum Pressure Campaign Escalates: OFAC Designates a Chinese Refiner of Iranian Crude
On March 20, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated the “teapot” Chinese oil refinery Shandong Shouguang Luqing Petrochemical Co., Ltd. (“Luqing Petrochemical”), its chief executive officer, eight vessels, and eleven vessel owners, managers, and operators, on OFAC’s List of Specially Designated Nationals and Blocked Persons (“SDN List”).
Client Alert: Coalition of the Willing: EU and UK, but Not the US, Impose New Russia Sanctions
As they have on each previous anniversary, the EU and UK released new sanctions against Russia on February 24, 2025, to mark the three-year anniversary of Russia’s full-scale invasion of Ukraine. For the first time, the United States did not do the same, electing to issue a limited set of Iran-related sanctions on the anniversary
Parting Shots by Biden Administration in the Form of Sweeping New Russia Sanctions
- On the 10th, OFAC and the State Department aggressively targeted the Russian energy sector by designating major Russian oil companies liquefied natural
UK’s OTSI Publishes New Russia Evasion and Diversion Guidance
To kick-start 2025, the UK’s recently established Office of Trade Sanctions Implementation (“OTSI”) has published two related guidance notes for UK exporters on Russian trade sanctions evasion and diversion.
First, Countering Russian sanctions evasion – guidance for exporters seeks to support UK exporters and manufacturers in identifying Russian evasion practices and mitigating the
OFAC Issues Necessary and Long-Awaited Updated Guidance for (Re)Insurance Industry
On November 13, 2024, the U.S. Department of the Treasury’s (“Treasury’s”) Office of Foreign Assets Control (“OFAC”) updated its FAQs for insurers in a long-awaited move to modernize its published sanctions compliance guidance for the insurance industry. None of the industry-specific FAQs had been updated since January 2015, and many had not been amended in
OFSI Granted Greater Sanctions Monitoring and Enforcement Powers
The UK Government has passed new amending sanctions regulations which grants its financial sanctions regulator – the Office of Financial Sanctions Implementation (“OFSI”) – greater intelligence gathering and enforcement powers, and enables OFSI to deal with licensing applications more efficiently.
The majority of the amendments introduced by The Sanctions (EU Exit) (Miscellaneous
Client Alert: New BIS Guidance Continues Trend of Enhanced EAR Compliance Expectations for Financial Institutions
In new guidance published on October 9, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued recommendations about its expectations for financial institutions in complying with U.S. export control obligations.
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Meet OTSI: New UK Trade Sanctions Enforcement Agency Launches
From Thursday October 10, 2024, the UK has an additional new sanctions regulator following the official launch of the Office of Trade Sanctions Implementation (“OTSI”). First announced in December 2023, its establishment was confirmed last month with the publication of The Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 (the “Regulations).