Sanctions Alerts - Trade Compliance

2022

  • International sanctions and export control

    2022

    Agreement on price cap on Russian crude oil

    Today, the fifth of December 2022, the G7 price cap policy for Russian crude oil takes effect. The price cap has been set to 60 dollars per barrel.

  • International sanctions and export control

    2022

    New EU sanctions regime on Haiti and EU Council adds sanctions violations to list of 'EU crimes'

    On 25 November 2022, the EU introduced for the first time a sanction regime on Haiti, aimed in particular at gang leaders and their financiers held responsible for the current security and humanitarian crisis in Haiti. In addition on 28 November 2022, the EU Council adopted a decision to add the violation of restrictive measures to the list of 'EU crimes'.

  • International sanctions and export control

    2022

    New Russia-related sanctions

    In light of Russia's escalating war against and illegal annexation of Ukraine, there have recently been developments to the Norway, UK and US sanctions regimes on Russia, as well as further sanctions designations from the EU, since our last update. In addition, G7 members have updated on the upcoming price cap exemption for the maritime transportation of Russian oil and oil products to third countries.

  • International sanctions and export control

    2022

    Changes to sanctions regimes on Haiti, Nicaragua and Iran, new export controls on China, and other developments

    Below we summarise the developments in EU, UK and US sanctions regimes that are not Russia-related.

  • International sanctions and export control

    2022

    EU imposes new round of sanctions on Russia

    Earlier today, 6 October 2022, the EU adopted another package of sanctions on Russia, in the wake of escalated Russian aggression against Ukraine, and in particular the in particular the organizing of the "sham referenda" and the illegal annexation of Ukrainian regions of Donetsk, Luhansk, Kherson and Zaporizhzhia.

  • International sanctions and export control

    2022

    Developments in Russia-related sanctions

    The recent weeks has seen a high level of activity from EU, US and UK sanctioning authorities, in response to escalated Russian aggression against Ukraine. In this WR Sanctions Alert, we briefly summarize some key developments.

  • International sanctions and export control

    2022

    Norway adopts the EU's sixth sanctions package against Russia

    Today, on 17 June 2022, Norway adopted additional Russia related sanctions, by largely implementing sanctions equivalent to the EU's sixth sanctions package (which was adopted by the EU on 3 June 2022).

  • International sanctions and export control

    2022

    The UK introduces new enforcement powers for breaches of financial sanctions

    New enforcement powers for sanctions breaches and accompanying guidance indicate a strengthening of UK sanctions enforcement going forward. Civil liability for breach of UK sanctions can as of today be imposed on a strict liability basis.

  • International sanctions and export control

    2022

    Additional Russia-related sanctions from the EU, UK, US and Norway and developments in Russian countermeasures

    Since our last update on 21 April 2022, the EU has adopted its sixth Russia related sanctions package, while Norway has aligned its sanctions regime with the EU's fifth sanctions package. Furthermore, the UK and US have introduced additional sanctions, and Russia has developed its countermeasures.

  • International sanctions and export control

    2022

    Further UK and US sanctions against Russia and developments in Russian countermeasures

    Since our last update on 11 April 2022, the UK has introduced new sanctions, the US has designated additional individuals end entities, and Russia has announced developments to its counter-measures. Furthermore, the EU and US have introduced certain exemptions to its sanctions regimes relating to humanitarian activities.

  • International sanctions and export control

    2022

    Additional US, EU and UK sanctions against Russia

    In view of the gravity of the Russian aggression against Ukraine, the US, the EU and the UK have adopted additional sanctions against Russia since our previous update on 5 April 2022.

  • International sanctions and export control

    2022

    Additional US, EU and UK sanctions against Russia, and new Norwegian sanctions

    Since our update on 14 March 2022, the EU, UK and US have announced additional sanctions following Russia's continued military aggression against Ukraine. In addition, Norway has implemented much of the EU sanctions imposed in the recent months.

  • International sanctions and export control

    2022

    More EU, US and UK sanctions relating to Russia

    On 11 March 2022 the EU, US and G7 made a coordinated announcement of additional sanctions against Russia in response to Russia's military aggression against Ukraine.

  • International sanctions and export control

    2022

    Further EU, UK and US sanctions relating to Russia and Belarus

    Since our previous update on 4 March 2022, the EU, UK and US have announced additional sanctions against Russia and Belarus in response to Russia's military aggression against Ukraine.

  • International sanctions and export control

    2022

    Update on Russian countermeasures against so-called "unfriendly states"

    In the last week, Russia has announced and implemented several countermeasures against so-called "unfriendly states", i.e. states that recently have imposed sanctions against Russia in response to Russia's military aggression against Ukraine.

  • International sanctions and export control

    2022

    Increasing US, EU and UK sanctions against Russia; Norwegian alignment with EU sanctions; new Russian countermeasures

    Since our previous update on 21 March 2022, the US and UK have implemented additional sanctions in response to Russia's continued military aggression against Ukraine, and Norway has aligned its regime with the latest EU sanctions. Russia has responded with additional countermeasures. We outline the main points of these developments below.

  • International sanctions and export control

    2022

    Additional EU, UK and US sanctions relating to Russia

    In the last 48 hours, the EU, UK and US have announced additional tranches of sanctions against Russia in response to Russia's military aggression against Ukraine.

  • International sanctions and export control

    2022

    Increasing EU, UK and US sanctions against Russia

    Following Russia's continued military aggression towards Ukraine, the EU, UK and US have adopted new sanctions against Russia since our last WR Sanctions Alert on 25 February 2022. We have summarised the main developments below.

  • International sanctions and export control

    2022

    New host of additional US, UK and EU sanctions against Russia

    In the last 48 hours, the US, UK and EU have announced a host of additional sanctions against Russia in response to its military invasion of Ukraine.

  • International sanctions and export control, Internasjonale sanksjoner og eksportkontroll

    2022

    New wave of US, EU and UK sanctions against Russia

    Yesterday, 22 February 2022, the US, UK and EU announced a new wave of sanctions against Russia. These sanctions build on those announced on 21 February 2022 and are a response to Russia's movement of troops across the Ukrainian border.

  • International sanctions and export control, Internasjonale sanksjoner og eksportkontroll

    2022

    New US sanctions in response to Russian aggression. EU sanctions to come

    Earlier this month, we noted the possibility of increase in US and EU sanctions against Russia, should Russia take aggressive steps towards Ukraine. Yesterday, 21 February, Russia took steps to recognise the so-called Donetsk People’s Republic (DNR) and Luhansk People’s Republic (LNR) regions of eastern Ukraine as independent entities.

  • International sanctions and export control

    2022

    Potential increase in US and EU sanctions against Russia

    As Russia continues its military build-up along the Ukrainian border, both the US and the EU warn of new sanctions that will be used against Russia if it takes aggressive steps. Reportedly, the US and EU are preparing a coordinated response to deter Russian military initiatives towards Ukraine, which they have stated would have "massive consequences" for Russia.

  • International sanctions and export control

    2022

    New Year Update: New US restrictions on narcotics trafficking, Xinjiang and Cambodia, and expanded EU sanctions framework on Mali

    During the weeks leading up to Christmas, the US adopted sanctions and other restrictions relating to narcotics trafficking, Xinjiang forced labour and Cambodia related exports and imports, whilst the EU has established an autonomous sanctions framework on Mali.

2021

  • International sanctions and export control

    2021

    US, UK, Canada and Switzerland further increase sanctions pressure on Belarus

    On 9 August 2021, the one year anniversary of the fraudulent presidential elections in Belarus, the US, the UK and Canada all imposed new measures aimed at the Lukashenka regime. Two days later, Switzerland imposed similar measures.

  • International sanctions and export control

    2021

    EU imposes sectoral sanctions on Belarus, updates on EU's Myanmar/Burma and Libya regimes

    Over the course of an eventful week, the EU, the US, the UK and Canada increased the sanctions pressure on Belarus considerably.

  • International sanctions and export control

    2021

    US makes changes to sanctions on Chinese military companies

    On 3 June 2021, President Biden issued a new Executive Order, making important changes to the sanctions regime aimed at companies involved with the Chinese military.

  • International sanctions and export control

    2021

    UK launches new Global Anti-Corruption sanctions regime

    On April 26, 2021, the UK launched a new sanctions regime, aimed at preventing and combatting serious corruption.

  • International sanctions and export control

    2021

    US imposes new sanctions on Russia

    On 15 April 2021, President Biden issued an Executive Order targeting a broad array of individuals and entities deemed by the US to be involved in malign activities directed by the Russian government.

  • International sanctions and export control

    2021

    The US prohibits transactions with 8 Chinese software applications

    On 5 January 2021, President Trump issued an "Executive Order Addressing the Threat Posed By Applications and Other Software Developed or Controlled By Chinese Companies," taking aim at makers of Chinese software applications.

  • Capital Markets, Financing

    2021

    What you need to know about the new UK sanctions regime post-Brexit

    As the Brexit transition period has recently come to an end, we highlight below some key differences brought about by the UK's new sanctions regime and what you need to know about the new regime.

2020

  • International sanctions and export control

    2020

    Potential expansions of US sanctions on China, Nord Stream 2/TurkStream pipelines, and Turkey

    The US Congress has passed the National Defense Authorisation Act for Fiscal Year 2021 (the "NDAA 2021"), and the annual defense spending bill is now pending President Trump's approval. Below, we briefly outline some key elements of the pending bill from a sanctions perspective.

  • International sanctions and export control

    2020

    The EU's new global human rights sanctions regime

    Yesterday, 7 December 2020, the EU adopted a new global human rights sanctions regime, equipping itself with a framework for targeting serious human violations and abuses.

  • International sanctions and export control

    2020

    Potential EU sanctions against Turkey in response to situation in Varosha

    On 26 November 2020, the European Parliament issued a resolution on the escalating tensions in Varosha, stressing the urgent need for the resumption of talks, and calling for "tough sanctions" on Turkey.

  • International sanctions and export control

    2020

    New Executive Order prohibits investments in Chinese Military Companies

    Amidst escalating tensions in US-China trade relations, President Trump last week issued an Executive Order ("the EO") on Addressing the Threat from Securities Investments that Finance Communist Chinese Military Companies

  • International sanctions and export control

    2020

    US amends North Korean Sanctions Regulations, imposes secondary sanctions

    Last week, the US Department of the Treasury's Office of Foreign Assets Control amended the North Korea Sanctions Regulations (31 CFR part 510, "the Regulations"). The revised Regulations implement the Treasury-administered provisions of the North Korea Sanctions and Policy Enhancement Act as amended by Countering America's Adversaries Through Sanctions Act and the National Defense Authorization Act for Fiscal Year 2020. The amendments include certain secondary sanctions, and took effect on 10 April 2020.

  • International sanctions and export control

    2020

    US imposes secondary sanctions over Nord Stream 2

    US imposes secondary sanctions over the Nord Stream 2 pipeline in Europe, currently under construction led by Russian state company Gazprom. The intention is to stop completion of the pipeline.

2019

  • International sanctions and export control

    2019

    New US (and potential EU) sanctions on Turkey

    Turkey's military offensive in north-east Syria has led to new US primary and secondary sanctions from the US and announcements of potential future sanctions from the EU.

  • International sanctions and export control

    2019

    Companies Transacting with Chinese Shipowners Face New Sanctions Risks

    Last week, the Trump Administration imposed sanctions against Chinese entities and individuals that it has determined have been trading in Iranian oil

  • International sanctions and export control

    2019

    OFAC announces changes in sanctions rules on Cuba

    In previous Sanctions Alerts, we have discussed the Trump administration's shift in its sanctions policy against Cuba. Last week, the Department of the Treasury's Office of Foreign Assets Control (OFAC) took additional steps intended to financially isolate the Cuban government.

  • International sanctions and export control

    2019

    New US sanctions against Venezuelan government

  • International sanctions and export control

    2019

    Update on US sanctions on Iran

  • International sanctions and export control

    2019

    New US sanctions against Mali

  • International sanctions and export control

    2019

    Update: US sanctions on Cuba

    Multiple lawsuits filed under Libertad Act

  • Internasjonale sanksjoner og eksportkontroll

    2019

    US threatens secondary sanctions relating to Nord Stream 2

    US threatens secondary sanctions over the European Nord Stream 2 pipeline. Foreign parties involved in the construction could be subject to future US sanctions.

  • International sanctions and export control

    2019

    Sanctions update regarding Iran

    On 24 June 2019, President Trump announced another set of sanctions targeting Iran.

  • International sanctions and export control

    2019

    US warns of potential sanctions relating to INSTEX and of sanctions on Iranian oil

    US warns of potential secondary sanctions on INSTEX

  • International sanctions and export control

    2019

    Significant shift in US extraterritorial sanctions against Cuba. US sanctions and EU regulations go head to head

    On 17 April 2019, the Trump Administration announced that US nationals will be allowed to file lawsuits against any person or company trafficking in Cuban confiscated property, before US courts. This by activating the long-suspended Title III of the Libertad Act. In his reasoning, the Secretary of State remarked that "Sadly, Cuba’s most prominent export these days is not cigars or rum; it’s oppression." The EU views the decision as contrary to international law and will, according to its High Representative, use the EU Blocking Regulation to prohibit EU persons from complying with it.

  • International sanctions and export control

    2019

    US will not renew Iran oil exceptions

    On 22 April 2019, the US Secretary of State Mike Pompeo announced, somewhat surprisingly, that the US will not renew any of the existing Significant Reduction Exceptions ("SRE"s) that were issued for eight countries on 3 November 2018. The decision aims to "bring Iran’s oil exports to zero", according to the White House, and underscores the US determination to expand and enforce its maximum pressure against Iran.

  • International sanctions and export control

    2019

    Possible future development in EU sanctions relating to Libya

    On 11 April 2019, the High Representative of the EU, Federica Mogherini, made statements that, by some, have been interpreted as a possible warning of further EU sanctions relating to Libya.

  • International sanctions and export control

    2019

    Development in US sanctions relating to Venezuela

    On 17 April 2019, OFAC designated Banco Central de Venezuela under Executive Order 13850, as amended, for operating within the Venezuelan economy. At the outset, this means that all dealings involving Banco Central de Venezuela, or entities owned 50 % or more by this bank, are prohibited if subject to US jurisdiction.

  • International sanctions and export control

    2019

    US extends sanctions on Somalia for 1 year

    On 10 April 2019, President Trump extended the US sanctions relating to Somalia for 1 year.

  • International sanctions and export control

    2019

    EU Council extends sanctions on human rights violations in Iran

    This week, the Council of the EU extended its restrictive measures responding to serious human rights violations in Iran.

  • International sanctions and export control

    2019

    US prolongs sanctions on South Sudan for 1 year

    On 1 April 2019, President Trump declared that the US sanctions in relation to South Sudan will continue for 1 year.

  • International sanctions and export control

    2019

    US considers Venezuela secondary sanctions

    Previously, we have informed of developments to the US primary sanctions on Venezuela. This week, the US indicated that also secondary sanctions might be on their way.

  • International sanctions and export control

    2019

    EU extends sanctions regimes on Egypt and on Bosnia and Herzegovina for 1 year

    The EU has extended its sanctions against Egypt for 1 year until 22 March 2020.

  • International sanctions and export control

    2019

    US renews legal basis for sanctions against Iran

    On 12 March 2019, the US renewed the legal basis for its sanctions against Iran.

  • International sanctions and export control

    2019

    US issues updated General License 7A in relation to sanctions against Venezuela

    Last week, we informed that OFAC had issued General Licences 3D and 9C relating to certain Venezuelan bonds and Petroleos de Venezuela S.A. ("PdVSA") securities. Yesterday, OFAC issued yet another General Licence relating to US sanctions against Venezuela.

  • International sanctions and export control

    2019

    Updated General Licenses in relation to the US Sanctions against Venezuela

    Previously, the US President has issued various Executive Orders ("EO"s) to stop the human rights abuses and antidemocratic actions of the regime of Venezuelan President Nicolas Maduro. Various General Licenses, issued by OFAC, do however provide exemptions from the EO provisions in order to minimize the impact on the Venezuelan people and US interests.

2018

  • International sanctions and export control

    2018

    EU lifts Eritrea sanctions

    On the 10th of December, the EU terminated its sanctions regime against Eritrea.

  • International sanctions and export control

    2018

    Norway lifts Eritrea sanctions

    Earlier this month, we informed that the UN has lifted its sanctions against Eritrea after nine years as a consequence of the improved political and military situation in the country.

  • International sanctions and export control

    2018

    UN lifts Eritrea sanctions

    On 14 November 2018, the UN Security Council adopted resolution 2444 (2018) terminating all UN restrictive measures against Eritrea with immediate effect.

  • International sanctions and export control, Compliance and crisis management

    2018

    What Do President Trump's Iran Threats Mean for Norwegian Companies?

    At last month's State of the Union address, President Trump called on Congress to "address the fundamental flaws in the terrible Iran nuclear deal". Trump has been attacking the deal, formally known as the Joint Comprehensive Plan of Action (the "JCPOA"), since he began campaigning for the presidency. But this latest statement, made at one of Washington's most important political events and coming on the heels of Trump's January 12 threat to withdraw from the JCPOA, suggests that the president may be closer to taking action. If Trump does decide to end US participation in the JCPOA, how will he do it? And what will this mean for Norwegian companies considering business in Iran?

  • International sanctions and export control, Compliance and crisis management

    2018

    Considerations for Norwegian Companies after the US Withdrawal from the Iran Nuclear Deal

    On May 8, President Donald Trump announced that the United States would withdraw from the Iran nuclear deal, otherwise known as the Joint Comprehensive Plan of Action ("JCPOA"), and re-impose the sanctions that the US had lifted under the deal. This will have important ramifications for Norwegian companies as the United States will quickly revert to the sanctions regime that existed before the JCPOA.