News

Sanctions and Export Controls

Update on US-Venezuela relations

22/12/2025

Intensified sanctions targeting Russian and Iranian shadow fleets; EU agrees to phase out Russian gas imports

Recent weeks have seen significant sanctions activity across multiple jurisdictions, with particular focus on Russia's shadow fleet, and the EU has reached a landmark agreement to permanently phase out Russian gas imports.

26/11/2025

Affiliates Rule Suspended as Dutch Nexperia Case Highlights Extraterritorial Impact

The US Department of Commerce has suspended its controversial Affiliates Rule for one year following negotiations with China, temporarily halting export controls that would have extended restrictions to thousands of foreign subsidiaries owned by listed entities. The suspension, effective through 9 November 2026, comes as part of a broader trade deal in which China has agreed to pause its expansive rare earth export controls. However, the Dutch government's extraordinary seizure of semiconductor manufacturer Nexperia demonstrates the far-reaching extraterritorial consequences of US-China trade tensions, with European companies and global supply chains caught in the crossfire.

23/10/2025

EU adopts 19th sanctions package; UK and US target oil majors Lukoil and Rosneft

Last week, the UK designated Russia's largest oil companies Lukoil and Rosneft on the asset freeze list. Last night, the US followed suit, designating both entities on the SDN list. Today, the EU adopted its 19th sanctions package, targeting the Russian shadow fleet and LNG exports.

03/10/2025

Iran sanctions - snapback of UN sanctions with additional autonomous measures imposed by the EU and UK

Recent developments have resulted in the full reinstatement of UN sanctions against Iran, targeting the country's nuclear and ballistic missiles programmes. This, in turn, has triggered the EU and UK to adopt even broader restrictions against certain sectors in Iran and against persons and individuals connected with Iran.

01/10/2025

New '50 percent rule' adopted by BIS to address diversion concerns

On 29 September 2025, the US Bureau of Industry and Security (BIS) introduced a significant expansion of US export control measures by adopting the 'Affiliates Rule' under the Export Administration Regulations (EAR). This means that end-user controls are applied also on companies owned at least 50% or more by entities on the list in scope.

19/09/2025

Recent Developments in UK, EU, and Norway

There have been recent developments in sanctions regimes across the UK, EU, and Norway, with particular focus on new designations, regulatory guidance, and price cap adjustments targeting Russian entities. The changes highlight increased enforcement and tightening of restrictions in response to ongoing Russian aggression against Ukraine.

05/09/2025

UK 'failure to prevent fraud' offence comes into force

The corporate offence of 'failure to prevent fraud', established by the Economic Crime and Corporate Transparency Act 2023 (ECCTA), is now in force as of 1 September 2025. This marks a significant new phase for large organisations with UK connections, which should now take steps towards active mitigation of fraud risks.

04/08/2025

Court decision reshapes sanctions risk assessment for shipowners

In a long-awaited decision, the English High Court has found that a Shipowner’s decision to refuse their Charterers' orders to load a cargo, on the basis that doing so would expose them to sanctions, was not a decision that a reasonable shipowner could reasonably have come to.

19/07/2025

The EU's 18th sanctions package and other key sanctions updates

Today, the EU adopted its 18th package of sanctions against Russia following the invasion of Ukraine in 2022, targeting primarily Russia's energy sector and banking sector. Additionally, there have been several other notable updates across various jurisdictions, including new measures in relation to Russian hybrid threats and updated sanctions targeting Iran, Syria, Haiti and Moldova.

20/06/2025

Relief in Syria sanctions – a brief summary of key updates from US, EU, UK, and Norway

On 23 May 2025, the US provided for an immediate relief of sanctions against Syria by the implementation of Syria General License (GL) 25. A few days later, the Council of the EU followed up with the adaptation of legal acts lifting all economic restrictive measures on Syria, apart from measures targeting security. Similar measures are also taken by UK authorities.

04/06/2025

China enhances sanctions countermeasures amidst escalating trade tensions

On 23 March 2025, China introduced the new Provisions on Implementing the Anti-foreign Sanctions Law (the "Provisions"), which took effect immediately. These Provisions are designed to protect what China perceives as lawful commercial interests against the extraterritorial application of sanctions or other restrictive measures. Given the increasing global trade tensions and the expansion of international sanctions, companies are at risk of being caught between incompatible rulesets.

02/06/2025

UK government guidance paves way for entry into force of failure to prevent fraud offence

In September 2025, the UK’s new corporate “failure to prevent fraud” offence introduced under the Economic Crime and Corporate Transparency Act 2023 (the "Act"), will come into force. The Act is part of the UK government's ongoing and wider efforts to reform corporate criminal enforcement in the UK, including to strengthen corporate accountability.

20/05/2025

New round of sanctions targeting the Russian shadow fleet

Today, the EU adopted its 17th package of sanctions against Russia following the invasion of Ukraine in 2022, targeting primarily the Russian shadow fleet. The new package follows in the footsteps of the UK, who announced their largest package of sanctions against the shadow fleet earlier in May. The UK also announced more than one hundred additional designations today.

25/04/2025

Further US Trade Restrictions and Export Controls Amidst Ongoing Trade War with China

On March 25, 2025, the US Department of Commerce’s Bureau of Industry and Security (BIS) added 80 entities from China, the United Arab Emirates (UAE), South Africa, Iran, Taiwan, and other countries to the Entity List for activities deemed contrary to US national security and foreign policy. This represents another measure in the ongoing trade war between the US and China.

24/02/2025

Three years of war: New sanctions adopted by the EU and the UK

As anticipated, the European Union has reached an agreement on its 16th sanctions package against Russia, and the UK has announced its largest package of sanctions against Russia since 2022. The new measures aim to intensify pressure on the Kremlin on the day of the third anniversary of Russia's full-scale invasion of Ukraine. This package highlights the EU and UK's continued commitment to weakening Russia's war capabilities and supporting Ukraine, despite the concerns regarding the US' potential pressure on the EU the alleviate sanctions against Russia.

14/01/2025

The US introduces extensive measures targeting the Russian energy sector and oil revenues

On Friday 10 January 2025, the US introduced extensive measures targeting the Russian energy sector and Russia's oil revenues. The measures include the designation of 183 vessels, many of which are deemed to be part of the Russian shadow fleet, as well as oil traders, oilfield service providers, marine insurance companies and energy officials. The UK also joined the US in sanctioning the two major Russian oil producers Gazprom Neft and Surgutneftegas.

18/12/2024

Updates on latest sanctions developments in the Iranian and Venezuelan sanctions programmes

In this sanctions alert, we seek to summarise some recent developments relating to US and EU sanctions.

16/12/2024

The EU's 15th package adopted today and latest developments in the EU, UK and US Russia sanctions programmes

The EU today adopted the 15th package of sanctions against Russia. We include a key summary of these new measures as well as further updates on recent developments relating to Norwegian, EU, UK and US sanctions.

09/10/2024

New EU sanctions framework under the Russia regime and entry into force of UK framework for enforcement of trade, aircraft and shipping sanctions

Yesterday, on 8 October 2024, the EU Council established a new framework under the Russia sanctions regime in response to hybrid threats from Russia. Tomorrow, 10 October 2024, will see the entry into force of the UK's new framework for enforcement of trade, aircraft and shipping sanctions.

07/10/2024

Expanded Norwegian export controls for critical goods and technologies and updates to the EU Dual-Use List

The Norwegian Ministry of Foreign Affairs recently announced significant amendments to the Export Control Regulations and introduced a new Annex of additional controlled goods. Additionally, several EU Member States have imposed unilateral export controls, and we note that the EU Dual-Use List has recently been updated.

24/06/2024

New package of sanctions from the EU and US, and other recent developments

In this sanctions alert we provide an update on recent developments in the EU, UK and US sanctions against Russia.

18/04/2024

Recent developments, including new US sanctions restricting imports of aluminium, copper and nickel and wind-down of General License on Venezuela

In this sanctions alert we seek to summarise recent developments relating to Norwegian, EU, UK and US sanctions, including US and UK prohibitions on import of certain Russian-origin metals, wind-down of transactions related to oil and gas sector operations in Venezuela, EU's minimum rules for prosecution of and penalties for violating EU sanctions, and the implementation of the EU's 12th and 13th package of sanctions against Russia into the Norwegian Ukraine Regulation.

13/03/2024

Sanctions issued following the two-year anniversary of the invasion

In this sanctions alert, we include updates on recent developments following the two-year anniversary of the Russian invasion of Ukraine.

15/02/2024

Are all state-owned Russian companies controlled by President Putin?

This was a question many asked after a recent judgment from the English Court of Appeal. Sanctions target those designated as well as those owned or controlled by designated persons. Understanding the precise scope of what constitutes ‘control’ under UK sanctions can be challenging. In this article we shed some light on this analysis, based on recent case law.

15/02/2024

Enforcing an award contrary to sanctions, an issue of ’public policy’?

The past few years have illustrated with a vast intensity the relevance of international sanctions for an ever expanding number of businesses and sectors. This backdrop has also led to a significant increase in sanctions related disputes, which in turn has led to discussions regarding enforcement of arbitral awards that contravene applicable sanctions.

15/02/2024

Expansion of the UK’s corporate criminal liability regime

The UK Economic Crime and Corporate Transparency Act 2023 (“the ECCTA”) was formally approved on 26 October 2023. Among the most significant reforms introduced by the ECCTA are the establishment of ‘failure to prevent fraud’ as a new UK corporate criminal offence, and a reform of the UK identification doctrine expanding the extent of corporate criminal liability for economic crimes. In this article, we highlight the details of these two key aspects of the Act, and explain how they will affect Norwegian companies with operations or subsidiaries in the UK.

15/02/2024

The Crackdown on Price Cap Evasion and the BIMCO Russian Oil Price Cap Scheme Clause for Charter Parties

The BIMCO Russian Oil Price Cap Scheme Clause was long-anticipated when it was published on 2 June 2023. There has since been growing concern that the original Price Cap Measures were easy to circumvent, and in this article we examine the impact of the latest measures to combat such evasion.

02/02/2024

Invites to the Sanctions and Anti-Money Laundering Day 2024

On February 15th, we open the doors for the Sanctions and Anti-Money Laundering Day 2024 in Oslo- with speakers including American sanction authorities (OFAC), American export control authorities (BIS), and the EU Commission.

24/01/2024

EU recent developments

The EU Council established a new sanctions framework targeting Guatemala. A new framework is also established by the EU for imposing restrictive measures against those who support, facilitate or enable violent actions by Hamas and the Palestinian Islamic Jihad.

19/12/2023

EU adopts 12th package of sanctions against Russia

The long-awaited 12th package of sanctions against Russia over its invasion of Ukraine was announced yesterday afternoon on the 18th of December. As expected, the package includes restrictions on additional goods of Russian origin, including diamonds, measures to strengthen the price cap on Russian oil and a significant amount of new designated individuals and entities.

26/10/2023

Collaborative report on use of sanctions as a human rights instrument and effectiveness of sanctions against Russia

A report published on 26 October 2023 outlines the increasing use of sanctions as a tool for protecting human rights, while highlighting the gaps in enforcement of sanctions against Russia, with a focus primarily on Europe. The report is a collaborative product by the Norwegian Helsinki Committee and risk analysis company Corisk, with contributions from Wikborg Rein and consultancy agency Rud Pedersen.

23/10/2023

The US introduces Venezuela sanctions relief

On 18 October 2023, OFAC issued three new general licences and amended three existing general licences related to Venezuela in response to the signing of an electoral roadmap agreement between the Venezuela Unitary Platform and the Maduro regime. These actions by the US introduces, among other things, a sanctions relief for the Venezuelan oil and gas sector and gold sector in support of the Venezuelan people. OFAC also published related FAQs.

20/10/2023

UK recent developments

In this article, we summarise the following recent developments relating to UK sanctions:

13/10/2023

EU recent developments – new sanctions framework for Sudan

On 9 October 2023, the Council of the European Union adopted a new sanctions framework to impose sanctions against those undermining the stability and political transition of Sudan.

10/10/2023

Recent developments in EU and UK sanctions

Over the past few weeks, there have been a number of developments relating to EU and UK sanctions. In this article, we summarise the following recent developments:

25/07/2023

Recent developments: Russia-related sanctions

Over the past few weeks, there have been a number of developments in the Norwegian, EU, UK and US sanctions regimes relating to Russia. In this article, we summarise the following recent developments:

29/06/2023

New asset freeze guidance from the Norwegian Ministry of Foreign Affairs

Earlier today, the Norwegian Ministry of Foreign Affairs (the "MFA") published an updated guidance on asset freeze measures. The guidance was originally published in 2018, and today's update adds additional guidance and reflects recent developments in legislation.

22/06/2023

EU adopts 11th package of sanctions against Russia. Developments in UK sanctions against Russia and Belarus

The long-awaited 11th package of sanctions against Russia over its invasion of Ukraine was announced earlier today, after EU ambassadors reached a consensus earlier this week. As expected, the package seeks to strengthen existing sanctions and crack down on circumvention.

08/06/2023

BIMCO Publishes Price Cap Clause for Charterparties

The long-anticipated BIMCO Price Cap Clause was published on 2 June 2023, in response to the price caps on Russian origin crude-oil and petroleum products introduced by G7, EU and others. In this article we take a practical first look at the clause in context.

31/05/2023

Charter payments and sanctions – an update from the Commercial Court

In a summary judgment relating to a dispute arising out of the charterers’ failure to make hire payments under bareboat charterparties, the Commercial Court provides guidance on the impact of sanctions on the parties’ obligations to make payment.

24/05/2023

Russia sanctions: further US and UK designations, expansion of US authorities, UK announces ban on Russian-origin diamonds, copper, aluminium and nickel

On 19 May 2023, coinciding with the first day of the G7 Summit in Hiroshima, both the US and the UK announced several new sanctions designations. In addition, the US has expanded sanctions authorities targeting certain sectors of the Russian economy and banned export of architecture and engineering services to Russia, and the UK has announced coming bans on Russian diamonds, copper, aluminium and nickel.

25/02/2023

Intensified sanctions targeting Russian and Iranian shadow fleets; EU agrees to phase out Russian gas imports

Affiliates Rule Suspended as Dutch Nexperia Case Highlights Extraterritorial Impact

EU adopts 19th sanctions package; UK and US target oil majors Lukoil and Rosneft

Iran sanctions - snapback of UN sanctions with additional autonomous measures imposed by the EU and UK

New '50 percent rule' adopted by BIS to address diversion concerns

Recent Developments in UK, EU, and Norway

UK 'failure to prevent fraud' offence comes into force

Court decision reshapes sanctions risk assessment for shipowners

The EU's 18th sanctions package and other key sanctions updates

Relief in Syria sanctions – a brief summary of key updates from US, EU, UK, and Norway

China enhances sanctions countermeasures amidst escalating trade tensions

UK government guidance paves way for entry into force of failure to prevent fraud offence

New round of sanctions targeting the Russian shadow fleet

Further US Trade Restrictions and Export Controls Amidst Ongoing Trade War with China

Three years of war: New sanctions adopted by the EU and the UK

The US introduces extensive measures targeting the Russian energy sector and oil revenues

Updates on latest sanctions developments in the Iranian and Venezuelan sanctions programmes

The EU's 15th package adopted today and latest developments in the EU, UK and US Russia sanctions programmes

New EU sanctions framework under the Russia regime and entry into force of UK framework for enforcement of trade, aircraft and shipping sanctions

Expanded Norwegian export controls for critical goods and technologies and updates to the EU Dual-Use List

New package of sanctions from the EU and US, and other recent developments

Recent developments, including new US sanctions restricting imports of aluminium, copper and nickel and wind-down of General License on Venezuela

Sanctions issued following the two-year anniversary of the invasion

Are all state-owned ­Russian ­companies controlled by ­President Putin?

Enforcing an award ­contrary to sanctions, an issue of ’public policy’?

Expansion of the UK’s corporate criminal liability regime

The Crackdown on Price Cap Evasion and the BIMCO Russian Oil Price Cap Scheme Clause for Charter Parties

Invites to the Sanctions and Anti-Money Laundering Day 2024

EU recent developments

EU adopts 12th package of sanctions against Russia

Collaborative report on use of sanctions as a human rights instrument and effectiveness of sanctions against Russia

The US introduces Venezuela sanctions relief

UK recent developments

EU recent developments – new sanctions framework for Sudan

Recent developments in EU and UK sanctions

Recent developments: Russia-related sanctions

New asset freeze guidance from the Norwegian Ministry of Foreign Affairs

EU adopts 11th package of sanctions against Russia. Developments in UK sanctions against Russia and Belarus

BIMCO Publishes Price Cap Clause for Charterparties

Charter payments and sanctions – an update from the Commercial Court

Russia sanctions: further US and UK designations, expansion of US authorities, UK announces ban on Russian-origin diamonds, copper, aluminium and nickel

EU adopts tenth package of sanctions on Russia

Sanctions and money laundering on the agenda

US and UK impose new sanctions on Russia

Are all state-owned Russian companies controlled by President Putin?

Enforcing an award contrary to sanctions, an issue of ’public policy’?