Morgan Lewis US and Russia Sanctions Update
What's Newest (cont'd)
European Union / UK
Routine sanctions extensions: Crimea to 23 June 2021, blacklist to 15 Sept. 2021, sectoral to
31 July 2021 - see slide 16
EU Council Reg. and Decision of 14 Oct. 2020 designating six Russian gov't officials (including
the FSB head) under 2018 chemical weapons proliferation/use reg. re the Navalny poisoning -
and further Decision of 2 March 2021 designating four Russian gov't officials (for Navalny
detention, and quelling related protests) under new Global Human Rights Sanctions Regime
UK - post-Brexit (see slides 84-85)
UK's own Russia sanctions regime replaced the EU regime as of 31 Dec. 2020
15 Oct. 2020 enforcement of sanctions against six Russian officials and a chemicals institute for the
alleged Navalny poisoning under the EU's chemical weapons sanctions regime (implemented then
under the UK Chemical Weapons (Sanctions) (EU Exit) Regulations 2019)
EU uncertainty re Nord Stream 2 situation, and conceivable Germany/US deal to resolve (and see
slide 7)
Recent court decisions of note - not involving Russia sanctions but relevance by analogy (and
see slide 58)
English Commercial Court decision of Nov. 2020, rejecting PDVSA's defense of US-sanctions-based
inability to repay USD loan amounts to a bank
Paris Court of Appeal (International Commercial Chamber) 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/using new INSTEX system as alternative to USD dealings in
some limited ways (this concerns the Iran sanctions but still noteworthy)
Morgan Lewis
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