Sanctions – National Security and International Trade Update

Implications of New “Secondary Tariff” Executive Order Targeting Importers of Venezuelan Oil

Mar 31 2025

By: Steven F. Hill, Guillermo S. Christensen, Jeff Orenstein, and Brian J. Hopkins

On 24 March 2025, the White House issued an Executive Order threatening to impose a 25% tariff on all goods imported into the United States from any country that imports Venezuelan oil directly or indirectly through third parties. Effective on or after 2 April 2025, the tariff is in response to alleged actions of Venezuela’s Maduro government, in particular sending members of the Tren de Aragua gang (designated a foreign terrorist organization) and other criminals into the United States and its involvement in kidnapping and violent attacks including the assassination of a Venezuelan opposition figure.

European Union Adopts 16th Package of Sanctions Against Russia, Further Impacting the Aviation Industry

Mar 21 2025

By: Laura Scott, Petr Bartos, and Michael Ruck

On 24 February 2025, the European Union adopted the 16th Russia sanctions package.

The new measures amending the framework Council Regulation (EU) 833/2014 are found and included in Council Regulation (EU) 2025/395. They target systemically important sectors of the Russian economy including energy, trade, transport, infrastructure and financial services. The new package also includes restrictions directly impacting the aviation industry, through the amendment to Article 3d, “the flight ban”, and the inclusion of Article 5ae, “a full transaction ban” on ports and airports in and surrounding Russia.

Below you will find a very brief note on the beforementioned articles.

European Union Adopts 16th Package of Sanctions Against Russia, Further Impacting the Aviation Industry

Mar 13 2025

By: Laura Scott, Petr Bartos, and Michael Ruck

On 24 February 2025, the European Union adopted the 16th Russia sanctions package.

EU Sanctions—Article 8a “Best Efforts” Explained

Feb 04 2025

By: Michael E. Ruck, Petr Bartoš, and Helen J. Phizackerley

On 24 June 2024, the European Union (EU) implemented its 14th package of sanctions against Russia to combat its continued aggression against Ukraine. A notable addition was made to Article 8a of Council Regulation (EU) No 833/2014, which introduced the requirement that EU operators “undertake their best efforts to ensure that any legal person, entity or body established outside the Union that they own or control does not participate in activities that undermine the restrictive measures provided for in [the] Regulation.” A similar clause has also been included in the Belarus sanctions framework.

New US Sanctions Target Russia’s Energy Sector

Jan 13 2025

By: Nate Bolin, Jeffrey Orenstein, Myeong Park, and Brian Hopkins

On 10 January 2025, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a package of new sanctions targeting Russia’s energy sector. In an effort to curtail Russia’s oil revenue and ability to evade US sanctions, OFAC issued: (1) a Determination authorizing sanctions on parties operating in Russia’s energy sector; (2) a Determination banning US petroleum services to Russia; and (3) blocking sanctions against oil and gas majors, vessels in the so-called “shadow fleet,” certain traders of Russian oil, Russian maritime insurers, and Russian oilfield service providers.

Top Tips for Sanctions Compliance and Preventing Sanctions Evasion

Nov 18 2024

By: Michael Ruck, Petr Bartoš, and Helen Phizackerley

On 24 September 2024, the G7 released updated guidance on the prevention of evasion of export controls and sanctions imposed on Russia.

This blog provides an overview of the guidance and the firm’s top tips for sanctions compliance and preventing sanctions evasion:

Tag:Sanctions