The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 23 Dec 2025 (UK):
The Office of Financial Sanctions Implementation ("OFSI") added seven FAQs (FAQs 177 to 183) to the UK Financial Sanctions FAQs, which relate to the Arbitration Costs General Licence INT/2025/5787748 ("Arbitration Costs GL" or "GL"). The GL applies to the Russia and Republic of Belarus sanctions regimes, pursuant to Regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019 (the "Russia Regulations") and Regulation 32 of the Republic of Belarus (Sanctions) (EU Exit) Regulations 2019 (the "Belarus Regulations"). The new FAQs seek to provide further clarification regarding:
- when arbitrators and/or arbitration associations should use the GL;
- the circumstances under which the GL applies to non-designated persons ("DPs") and their representatives;
- what payments are covered by the GL;
- whether arbitrations occurring outside the UK engage UK sanctions;
- whether arbitrators can use surplus payment from one arbitration towards the deposit for another arbitration involving the same DP;
- whether DP and non-DP payments towards arbitration costs must be reported to OFSI; and
- which General Licence legal advisers representing DPs in arbitrations should use to comply with UK sanctions.
- 22 Dec 2025 (EU):
The Council of the European Union (the "Council") issued Council Decision (CFSP) 2025/2648, which extended the European Union's ("EU") sanctions imposed against Russia (pursuant to Council Decision 2014/512/CFSP) by six months until July 31, 2026.
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