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.

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.

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.

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

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.

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.

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.

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Associate

Marie works with compliance and crisis management. She works broadly within the firm's compliance practice, including anti-money laundering, anti-corruption, human rights and responsible business conduct, with her core areas being international sanctions and export control. 

Marie assists international companies with preventive and responsive compliance. She works for clients across various sectors, including industry, shipping, and finance. She also has experience from being on secondment with an international maritime operator, where she worked as a sanctions advisor.

Oslo

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Marie works with compliance and crisis management. She works broadly within the firm's compliance practice, focusing primarily on international sanctions and trade compliance