Takeaways Sanctions operate prospectively and do not affect payment obligations to a non-sanctioned party accruing before sanctions became effective. Payment obligations under standby letters of credit at issue were autonomous and unconnected with the underlying transaction. The fulfilment of an independent obligation owed by a German bank to Irish-incorporated aircraft lessors was found not to have intended to benefit the Russian entities involved in other elements of the transaction. The English Court recently confirmed that sanctions do not excuse non-payment to a non-sanctioned party whe ..read more

On February 24, 2023, the one-year anniversary of the Russia-Ukraine conflict, the United States released extensive new measures designed to impose additional sanctions on Russia for its aggression against Ukraine. These new measures are summarized below ..read more

On February 24 and 25, 2023, the United Kingdom and European Union each adopted additional sanctions against Russia due to the ongoing conflict in Ukraine. These new measures are summarized below ..read more

This post marks the third entry in our Year-in-Review series. For prior posts, click here. Many of the first measures that the United States, European Union and United Kingdom collectively took against Russia in 2022 related to aircraft and international air travel. As the conflict broke out, each jurisdiction quickly prevented Russian actors from entering their airspace. Over the past year, export controls on the aviation industry and sanctions on companies that support the Russian aviation sector have grown increasingly complex. Those rules have also been applied to Russia’s ally, Belarus. M ..read more

This post marks the second entry in our Year-in-Review series. For prior posts, click here. Few sectors have been more affected by the sanctions on Russia than the energy industry. As Russia’s largest industry, it has been a focus of sanctions designed to deter the continuation and escalation of the conflict in Ukraine, with policies targeting the trade in oil and gas, new equity and debt, investment in energy projects, and export to Russia of equipment and parts, as well as designations of specific companies and individuals in the sector. Russia remains one of the world’s largest suppliers of ..read more

On February 24, 2022, Russia’s entry into Ukraine set off an unprecedented wave of sanctions and export controls by a wide coalition of countries, including the United States, the United Kingdom, the European Union, Canada, Japan, South Korea, Australia, and New Zealand.  The goal of these measures is to cripple the Russian economy and its military capability, and they have had a widespread impact—both direct and indirect—on a broad array of global industries. Although the sanctions and export controls imposed by the international community are largely uniform in theme, they vary meaningf ..read more

On December 5, 2022, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) announced a $60 per barrel price cap on maritime transfers of Russian-origin crude oil. The final cap level is being implemented multilaterally by the Price Cap Coalition, which include the Group of 7 (G7) nations and Australia ..read more

Various reports indicate that the Group of Seven nations (G7) will announce its initial capped price for Russian-origin crude oil transported by maritime means (“seaborne”) this week. The cap will come into effect on December 5, 2022 for crude oil (including condensate) and February 5, 2023 for petroleum products. U.S. guidance issued on September 9, 2022 and EU and UK regulations issued in October and November 2022 have provided key details that may help companies and financial institutions prepare for compliance and recordkeeping ..read more

In the final few days of September, the U.S. and global allies issued a number of sanctions and export controls against actors who have supported Russia’s referendums in Ukraine and related attempts to annex four Ukrainian territories. The referendums have been condemned by the Group of 7 (G7) nations, which committed to imposing further economic costs on individuals and entities both inside and outside of Russia. The latest measures include actions by the Office of Treasury’s Office of Foreign Assets Control (OFAC), the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), the ..read more

In response to Russia’s invasion of Ukraine, and Belarus’s role in enabling this attack, the United States and global allies have imposed sweeping sanctions and export control restrictions on both Russia and Belarus. These actions are discussed extensively in our prior publications. The sanctions and export controls restrictions especially target Russia and have had a significant impact on the Russian economy. Virtually every industry is impacted, and Russia’s financial institutions, businesses and prominent individuals are being targeted by ever-widening sanctions and export control restricti ..read more