On December 2, 2025, OFAC announced an ~$11 million penalty settlement with IPI Partners, LLC (“IPI”), a Chicago-based U.S. private equity fund, to settle its civil liability for 51 potential violations of OFAC’s Russia sanctions. The enforcement action underscores the importance of diligence to guard against potential sanctions violations. In brief, OFAC found that IPI
Russia Sanctions
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…
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…
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…
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…
EU Implements Long-Awaited “14th Round” of Sanctions Against Russia, Further Targeting Circumvention, LNG and the Transportation Sector
An overview on new Russian sanctions and export controls issued by the European Union, focusing on anti-circumvention measures and the Russian financial, military, and LNG industries.
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Pressure Rising: New U.S. and UK Sanctions and Export Controls Increase Risks for Lingering Russia Exposure, Indirect Evasion in the Supply Chain, and IT Support for Russia Operations
An overview on new Russian sanctions and export controls issued by the U.S. (OFAC and BIS) and the UK focusing on the Russian financial, military, and LNG industries.
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U.S. Tightens Sanctions on Russia, Now Targeting Companies Based in China
On Wednesday, May 1, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that it issued new sanctions on nearly 200 entities and individuals for supporting Russia’s invasion of Ukraine, intensifying U.S. efforts to thwart Russia’s attempts to circumvent Western sanctions. The list includes more than a dozen of companies…
OFAC issues Russia-related General License 83A
On February 20, 2024, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) issued Russia-related General License (GL) 83A, “Authorizing Certain Transactions Related to Imports of Certain Categories of Fish, Seafood, and Preparations Thereof Prohibited by Executive Order 14068.”
On March 11, 2022, President Biden issued EO 14068 to prohibit, among other…