Regulatory & International Trade | RIT
Helping Businesses Clear Regulatory Hurdles in Europe
Regulatory & International Trade | RIT
Regulatory & International Trade | RIT
Helping Businesses Clear Regulatory Hurdles in Europe

Quarterly Sanctions Update | Q1 2024

The EU and the UK continue in their efforts of tightening sanctions against Russia, particularly in the context of the second anniversary of the Russia’s invasion of Ukraine and the sudden death of the Russian opposition leader Alexei Navalny. In this Quarterly Sanctions Update, McDermott Sanctions and Export Controls team summarizes the most recent and significant legislative amendments, as well as changes to the existing guidance, introduced between December 2023 and April 2024.

Notably, EU companies with presence in Russia will no longer be able to rely on the “partner countries subsidiary” exemption after 20 June 2024 and will be required to obtain individual licences to provide business services to their Russian entities. The processing time, information and documents relating to licence applications may vary depending on the EU Member State; for example the French competent authority requires operators to provide company specific information as well as description of services as of April 20, 2024 via Téléservice platform. Licences will also be required under a new prohibition relating to the provision of software for the management of enterprises, industrial design, or manufacture. Finally, EU exporters will need to ensure that they insert “no Russia clauses” in their agreements, prohibiting the re-export of their goods to Russia or for use in Russia.

Amendments to existing sanctions have been further accompanied with other legislative proposals, which we summarise in our Quarterly Sanctions Update.

Click here to read our full Quarterly.

Raminta Dereskeviciute
Raminta Dereskeviciute focuses her practice on product compliance, trade regulation (sanctions and export controls) and ESG. She has significant experience in advising on EU and UK chemical legislation (REACH), product safety and liability rules and frequently represents clients before the European Chemicals Agency Board of Appeal. Raminta also advises businesses on the implications Brexit has in relation to a range of regulatory compliance issues.

Sabine Naugès
Sabine Naugès counsels clients on all aspects of public law, including administrative and regulatory, competition and constitutional law. Among other high-profile clients, Sabine has advised telecommunications companies France Télécom and Orange on regulatory matters in cases before administrative and commercial courts, and before EU and French competition authorities. She also regularly represents major companies with interests in a wide range of industries, including aerospace, energy, oil and gas, and public health care, before the French government and in litigation, in a range of regulatory and administrative matters.

Michal Chajdukowski
Michal Chajdukowski focuses his practice on a range of regulatory and trade related matters. Drawing on his experience in financial regulation, he guides national and multi-national clients through the complexity of the UK and EU sanctions regimes and export controls, with a keen eye to cross-border commercial transactions.




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