The EU has adopted its 20th package of sanctions in connection with Russia’s ongoing war against Ukraine, resolving a prolonged internal political deadlock that had been caused by vetoes from Hungary and Slovakia. The package amends Regulations 833/2014, 269/2014, and 765/2006 and the respective Council Decisions and Implementing Regulations. The texts entered into force on
OFSI Imposes £390,000 Penalty on Apple Subsidiary for Russian Sanctions Breaches: Key Compliance Takeaways
The UK’s Office of Financial Sanctions Implementation (OFSI) has published details of a £390,000 penalty it imposed on ADI, an Irish subsidiary of Apple Inc., on 19 March 2026. The penalty relates to two payments totalling approximately £635,000 made in 2022 to Okko LLC, a sanctioned Russian app developer, for App Store revenue. Although the
Senate Committee Advances Bill to Shield U.S. Companies from Foreign Judgment Enforcement in the United States Relating to U.S. Sanctions Compliance
On March 26, 2026, the Senate Judiciary Committee advanced S.2934, the Protecting Americans from Russian Litigation Act of 2025 (the Bill), introduced by Senators John Cornyn (R-TX) and Alex Padilla (D-CA) in September 2025. The Bill is intended to address situations where U.S. companies that exited Russia to comply with U.S. sanctions following Russia’s
Move to a Single List for UK Sanctions Designations
From Wednesday, 28 January 2026, the UK Sanctions List (“UKSL”), published by the Foreign, Commonwealth and Development Office, will act as the sole source of UK sanctions designations made under the Sanctions and Anti-Money Laundering Act 2018 (“SAMLA”). OFSI’s Consolidated List of Asset Freeze Targets (the “OFSI List”) and its
Treasury Authorizes Transactions with Belarusian Potash Companies
On December 15, 2025, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Belarus General License 13, “Authorizing Transactions Involving Joint Stock Company Belarusian Potash Company, Agrorozkvit LLC, and Belaruskali OAO.” The general license authorizes all transactions prohibited by the Belarus Sanctions Regulations, 31 CFR part 548 (“BSR”), involving Joint Stock Company
European Commission Revises Dual-Use List: Highlights from the 2025 Update
On November 15, 2025, the implementing regulation updating the EU’s Dual-Use Regulation (Regulation (EU) 2021/821) came into force. The update incorporates editorial refinements for greater clarity and coherence, introduces new entries, and further clarifies some existing ones.
These updates reflect the EU’s efforts to harmonize its export controls with recent decisions and commitments
Key Takeaways from a Consequential Month of Russia-Related Sanctions
The United States, European Union, and United Kingdom have significantly escalated Russia-related sanctions the past month, including the Trump Administration’s first sanctions directly imposed on Russia. These coordinated actions—which particularly target the Russian energy sector—indicate that Russia sanctions remain on the geopolitical agenda and require multinational companies to remain vigilant in their compliance with those
EU Adopts 19th Sanctions Package Against Russia
- LNG Import Ban: The EU will prohibit the purchase, import, or transfer, directly or indirectly, of Russian liquified natural gas (LNG) from 25
UK Sanctions Lukoil, Rosneft in Major Russia Sanctions Expansion
On October 15, 2025, the UK announced a significant expansion of its Russia-related sanctions regime, designating Lukoil and Rosneft—Russia’s two largest oil companies—as asset freeze targets.
This is the first time Lukoil and Rosneft have been subjected to full asset freezing sanctions by any of the UK, U.S., or EU, and follows earlier UK measures
The EU and UK Act to Implement the Iran Sanctions “Snapback”
The snapback of UN sanctions on Iran took effect on September 27, 2025, after the E3 (France, Germany, UK) triggered the mechanism under UN Security Council Resolution 2231 and the Security Council failed to extend sanctions relief. Please see our previous Alert on the snapback process and what this could mean for global businesses.
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