Morgan Lewis US and Russia Sanctions Update
EU Sectoral Sanctions (cont'd)
And now, with Brexit done as of 31 Dec. 2020, the EU sanctions no
longer apply in UK
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Replaced by UK's own essentially identical (for now) regime
But emerging interpretive differences between the EU and UK Regs already
create some real questions (see slides 84-85 below, and FT report)
Energy
Per the initial July 2014 energy-sector sanctions regime (Reg. art. 3):
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Prior authorization is required for sale, supply, transfer or export, directly or
indirectly, of the items listed in Annex II (see link to the Reg. at slide 16)
➤ to any person or entity in Russia or elsewhere
if for use in Russia (clarified to include its EEZ and Continental Shelf - but not
clear whether includes Russian sector of Caspian Sea)
Authorization is to be considered / granted by competent authority "of the
member state where the exporter is established", per other EU rules
Morgan Lewis
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