The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 18 Dec 2025 (UK):
The Office of Financial Sanctions Implementation ("OFSI") issued General Licence INT/2025/8202932 ("GL INT/2025/8202932" or "GL"), pursuant to the Russia (Sanctions) (EU Exit) Regulations 2019 (the "Russia Regulations"). The GL allows for Persons to wind down from any transactions involving DPs or any Subsidiary (both defined in the GL) to which that Person is a party, including the closing out of any positions. Capitalized terms not otherwise defined in this entry shall have the meanings given to such terms in the GL.
- 18 Dec 2025 (UK):
The Office of Financial Sanctions Implementation ("OFSI") designated five individuals and 19 entities, pursuant to the Russia (Sanctions) (EU Exit) Regulations 2019 (the "Russia Regulations").
- 18 Dec 2025 (EU):
The Council of the European Union (the "Council") added 41 vessels to Annex XLII to Regulation (EU) No. 833/2014, as amended by Council Regulation (EU) 2025/2618 ("Regulation 2618"). The listed vessels are now subject to an EU port access ban, a prohibition on the provision of services related to maritime transport (e.g., crewing, operating, chartering etc.), as well as other forms of engagement.
- 17 Dec 2025 (EU):
The European Commission (the "Commission") updated the Russia sanctions FAQs relating to EU restrictions on diamonds, pursuant to Article 3p of Council Regulation (EU) No. 833/2014 ("Regulation 833").
- 17 Dec 2025 (UK):
The Office of Financial Sanctions Implementation ("OFSI") amended General Licence INT/2025/7323088 ("GL INT/2025/7323088" or "GL") to clarify that the definition of "Legal Services" includes legal advice and/or representation in dispute resolution. The GL applies to the UK Autonomous Sanctions Regimes listed in Annex 1, which includes the Russia (Sanctions) (EU Exit) Regulations 2019.
- 17 Dec 2025 (UK):
The Office of Financial Sanctions Implementation ("OFSI") added one FAQ (FAQ 175) to the UK Financial Sanctions FAQs ("FAQs") to clarify whether legal services received during a dispute resolution are covered by the Legal Services General Licence INT/2025/7323088 (the "GL"). The GL applies to the UK Autonomous Sanctions Regimes listed in Annex 1, which includes the Russia (Sanctions) (EU Exit) Regulations 2019.
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