US Sectoral Sanctions

What's Newest (cont'd) European Union / UK Routine sanctions extensions: Crimea to 23 June 2021, sectoral to 31 Jan. 2021, blacklist to 15 March 2021) - see slide 18 ECJ (EU's highest court) decisions of 25 June 2020 rejecting VTB and VEB and 17 Sept. 2020 rejecting Rosneft final appeals from the EU's imposition of sanctions against them EU Commission Opinion of 19 June 2020 re financial and other transactions with non-designated entities owned or otherwise controlled by a designated (i.e., blocked) person - this ruling not being specific to the Russia sanctions (see slide 82) EU Council Reg. and Decision of 14 Oct. designating six Russian gov't officials (including the FSB head) under 2018 chemical weapons proliferation/use regulation, in connection with the Navalny poisoning UK / Brexit: EU sanctions remain in effect in the UK until at least 31 Dec. 2020, but - - - UK adopted its own Russia sanctions in April 2019, effective 31 Jan. 2020 (see slide 83); similar to the EU sanctions, but some differences Now a fresh June 2020 UK "Guidance for the financial and investment restrictions" re the Russia sanctions: updates the original May 2019 Guidance, and now with UK FAQs (see slide 84) And most recent Nov. 2020 House of Lords letter inquiry and Foreign Secretary response re UK sanctions policy post-31 Dec. 2020 transition period Also the new "UK Magnitsky Act" of July 2020 - see slide 84 below UK gov't has also announced intention to crack down on Russian oligarchs' "money laundering” in/through UK Some EU consideration of responsive measures to the US anti-Nord Stream 2 sanctions (and see slide 8) Recent court decisions of note - not involving Russia sanctions but relevance by analogy (and see slide 60) English Commercial Court decision of 4 Nov., rejecting PDVSA's defense of US-sanctions-based inability to repay USD loan amounts to a bank Paris Court of Appeal (International Commercial Chamber) fresh Dec. 2020 decision rejecting French contractor's defensive reliance on US secondary sanctions re contract with Iranian entity EU states are reported to be testing new INSTEX system as alternative to USD dealings (this concerns the Iran sanctions but still noteworthy - and also pending new Biden Admin. policy toward Iran) Morgan Lewis 14

View entire presentation