The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 03 Jul 2025 (UK):
The Akin Summary document has now been posted for this action.
The Office of Financial Sanctions Implementation ("OFSI") published four new sanctions FAQs (FAQs 149-152) of relevance to the UK's Russia sanctions regime, concerning the definition of an economic resource, licenses issued by an overseas territory, and securities held at designated local Russian registrars. FAQs 123-124 were moved to the withdrawn FAQs.
- 27 Jun 2025 (UK):
The Akin Summary document has now been posted for this action.
The Office of Financial Sanctions Implementation ("OFSI") amended General Licence INT/2022/2470156, which permits in respect of specific projects listed in Schedule 1 of the Licence (i) the supply or delivery of Russian oil by ship from a place in Russia to a third country or from one third country to another third country; and (ii) a service provider to provide relevant services to any person (whether or not a UK Person) relating to the supply or delivery of Russian oil by ship from a place in Russia to a third country or from one third country to another third country.
- 27 Jun 2025 (UK):
The Akin Summary document has now been posted for this action.
The Office of Financial Sanctions Implementation ("OFSI") amended General Licence INT/2025/5635700, which allows for the continuation of business operations with Gazpromneft-Sakhalin LLC, to the extent they are in relation to the Exempt Projects (as defined under General Licence INT/2025/5635700).
- 27 Jun 2025 (UK):
The Akin Summary document has now been posted for this action.
The Foreign, Commonwealth and Development Office ("FCDO") published new sanctions guidance to support non-UK businesses.
The guidance specifically concerns sanctions targeting Russia and summarizes the scope and requirements of UK sanctions, and outlines the risks of non-compliance for non-UK businesses. The guidance provides practical advice on how to implement good compliance practices, and mitigate the circumvention of UK sanctions. The guidance includes country-specific guides for businesses in Armenia, Georgia, Kazakhstan, Kyrgyzstan, and Uzbekistan. The guidance is general, so relevant up-to-date legislation should be consulted.
The OverRuled: China Trade Controls Resource Center has been updated with the following actions:
- 09 Jul 2025 (OFAC):
OFAC imposed sanctions on 22 entities based in Hong Kong, the UAE, and Türkiye, pursuant to EO 13224, for their roles in facilitating the sale of Iranian oil that benefits the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF). Iran uses these designated front companies as part of its network to help sanctioned Iranian government entities generate revenue from the sale of petroleum and other commodities subject to U.S. sanctions, and uses these proceeds to fund its weapons programs and support its terrorist proxies and partners across the Middle East.
Today's action marks the second round of sanctions targeting Iran's "shadow banking" infrastructure since the President issued National Security Presidential Memorandum 2 on February 4, 2025.
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