Russia Sanctions: The UK designated 63 individuals this week, including several war correspondents embedded with Russian forces in Ukraine that work at Channel One, a major state-owned media outlet in Russia. The UK also designated one entity, Evraz PLC, a UK-incorporated holding company of a multinational steel manufacturing and mining company group. Additionally, the

Michelle Linderman
Crowell & Moring Webinar – Forced Labor
Please join us for an update from our Supply Chain and Forced Labor team on the current state of the Uyghur Forced Labor Prevention Act (UFLPA), U.S. Customs and Border Protection (CBP) withhold release orders (WRO), findings, and how to successfully modify a WRO, submit WRO detention responses that work, and the timeline to have…
Russia Sanctions/Export Highlights [As of March 10, 2022]
Russia Sanctions: The U.S., EU, and UK continue to apply pressure on Russia through new sanctions on oligarchs and politicians and restrictions on exports. A number of other countries have implemented similar measures and continue to widen the scope of such prohibitions as the invasion continues. On a more limited scale, Belarus has also…
European Commission Issues a Proposal for a Directive on Corporate Sustainability Due Diligence
On February 23, 2022, the European Commission adopted a new proposal for a directive on corporate sustainability due diligence. The proposed directive specifically focuses on corporate responsibility in global supply chains with regards to human rights – such as child and forced labor – and the environment. This proposed directive comes nearly a year after…
U.S., EU and UK Escalate Belarus Sanctions
On December 2, 2021, the United States, the European Union (“EU”), the United Kingdom (“UK”) and other allies took coordinated action to designate various individuals, entities, and aircraft connected to human rights abuses by Belarussian President Alexander Lukashenko and his regime. This builds on asset freezing actions by the U.S., UK, EU, and Canada earlier…
CFIUS Has Definitively Crossed the Atlantic, but Is Yet to Complete Its U.K. Landing
The U.K.’s National Security and Investment Bill was enacted into law as the National Security and Investment Act (the “NSI Act”) on 29 April 2021, with the new regime expected to come into force towards the end of this year. Over the coming months the U.K. government is to enact secondary legislation and…
OFAC Revokes Belarus General License (General License 2G or GL 2G)
On April 19, 2021, the Office of Foreign Assets Control (“OFAC”) issued Belarus General License 2H (“GL 2H”) revoking General License 2G (“GL 2G”), which was due to expire on April 25, 2021.
For more than five years, OFAC regularly extended GL 2 G, and earlier versions of it, authorizing U.S. person activity with the…
UK and Canada Announce New Measures to Combat Forced Labor and Human Rights Violations
On January 12, 2021, the United Kingdom’s Foreign Secretary, as well as Canada’s Minister of Foreign Affairs and Minister of Small Business, Export Promotion, and International Trade, made parallel announcements outlining new measures to combat forced labor and human rights violations. The announcements come in the context of rising global concerns over reports of forced…
EU Adopts Magnitsky-Like Sanctions Program
On December 7, 2020, The Council of the European Union adopted a global human rights sanctions regime, similar to the Magnitsky Sanctions program used by the Department of the Treasury’s Office of Foreign Assets Control (OFAC). The EU’s framework will permit it to target individuals, entities, and bodies, whether state or non-state actors, and…
Iran Triggers Dispute Resolution Mechanism Under JCPOA
On July 3, 2020 Iran initiated a dispute resolution mechanism contained in the Joint Comprehensive Plan of Action (JCPOA), more commonly referred to as the Iran nuclear deal, to address concerns over implementation of the deal. The EU’s Foreign Policy Chief stated that he had received a letter from Iran triggering the dispute mechanism over…