US Sectoral Sanctions
EU Sectoral Sanctions (cont'd)
And now must have in mind Brexit
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The EU sanctions continue to apply in UK during the transition period
(i.e., at least to 31 Dec. 2020)
But independent UK rules have already been adopted
And emerging differences between the EU and UK Regs already create some
real questions (see slide 84 below, and FT report)
Energy
Per the initial July 2014 energy-sector sanctions / authorization 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 18)
➤ 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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