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.
Navigating EU Sanctions: How Investment Funds and Corporates Can Meet the ‘Best Efforts’ Standard
By Raminta Dereskeviciute, Sabine Naugès, Renate Prinz, Michal Chajdukowski and Ludovica Rabitti on Nov 29, 2024
Posted In Foreign Investment, Sanctions & Export Control
With the introduction of the 14th sanctions package, entities established in the European Union are required to ‘undertake their best efforts to ensure’ that non-EU subsidiaries they own or control do not undermine EU Regulation 833/2014 imposing EU sanctions against Russia, or EU Regulation 765/2006 imposing EU sanctions against Belarus. This obligation stretches to EU...
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New US Sanctions Against Gazprombank and Several Russian Financial Institutions
By Sabine Naugès, Raminta Dereskeviciute and Michal Chajdukowski on Nov 25, 2024
Posted In Sanctions & Export Control, Energy
The US Treasury’s Office of Foreign Assets Control (OFAC) has implemented sanctions on additional Russian financial institutions, notably Russia’s Gazprombank and several foreign subsidiaries. These blocking sanctions prohibit US persons and entities from transacting with Gazprombank or its listed subsidiaries, as well as any entity owned 50% or more by Gazprombank or any other sanctioned...
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Understanding French Export and Re-Export Prohibitions: Ministry of Armed Forces Releases FAQ on Non Re-Exportation Certificates
By Sabine Naugès and Michal Chajdukowski on Nov 22, 2024
Posted In France, Sanctions & Export Control
On October 10, 2024, the French Ministry of Armed Forces released an FAQ relating to a Non-Re-Exportation Certificate (NRC), available in French here (FAQ). This document provides practical guidance to military companies exporting equipment covered by the prohibition on export or re-export to sanctioned countries. The FAQ complements the existing guidelines for completing certificates required...
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Quarterly Sanctions Update | Q3 2024
By Raminta Dereskeviciute, Sabine Naugès and Michal Chajdukowski on Oct 8, 2024
Posted In Sanctions & Export Control
Although the European Union and the United Kingdom did not introduce new sanctions against Russia over the summer, they extensively focused on the implementation of the existing measures and their enforcement. This week, however, a new package of sanctions aimed at tackling hybrid operations by the Russian government has been agreed upon, and is expected...
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EU Member States Implement Additional Measures to Regulate Export of Non-Listed Dual-Use Items
By Raminta Dereskeviciute, Sabine Naugès and Michal Chajdukowski on Oct 4, 2024
Posted In Sanctions & Export Control
Member States in the European Union have taken additional measures beyond Regulation (EU) 2021/821 to control exports of dual-use items. More than half have extended authorization requirements for non-listed dual-use items suspected of being intended for military “end-use.” Additionally, five Member States have imposed export authorization for cyber-surveillance items linked to internal repression and serious...
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EU Court of Justice Upholds Confiscation of Proceeds from Brokering Services Relating to Russian Goods
By Sabine Naugès and Michal Chajdukowski on Sep 13, 2024
Posted In Sanctions & Export Control
Highlights In a recent ruling, the Court of Justice of the European Union (CJEU) upheld the legality of confiscating the proceeds from brokering services relating to military equipment manufactured in Russia and sold from Ukraine to India, without entering the European Union. This decision highlights the increasingly broad reach of EU sanctions and the EU’s...
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Quarterly Sanctions Update | Q2 2024
By Sabine Naugès, Raminta Dereskeviciute and Michal Chajdukowski on Jul 8, 2024
Posted In Sanctions & Export Control
On June 24, 2024, the European Union adopted its 14th sanctions package. While the focus of this package was to curb the violation and circumvention of sanctions through the introduction of due diligence obligations for non-EU subsidiaries, or the expansion of “no re-export to Russia” clause requirement, ample other amendments were also introduced, such as...
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Spotlight on the “Partner Countries” Exemption from Sanctions against Russia
By Raminta Dereskeviciute, Fabio Cozzi, Sabine Naugès, Dr. Alexa Ningelgen, Renate Prinz, Michal Chajdukowski, Benoit Feroldi, Kai Grandpierre and Dr. Tim Oliver Weill on Jun 7, 2024
Posted In Sanctions & Export Control
From June 20, 2024, EU companies with a presence in Russia will no longer be able to rely on the “partner countries” exemption and will be required to obtain, or rely on, a licence to provide business services and/or software to their Russian entities. Competent authorities of the EU Member States responsible for granting licences...
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New UK Securitisation Framework | Regulators Publish Final Rules
By Ranajoy Basu, Priya Taneja, Vlad Maly, Kevin Cummings, Siddhartha Sivaramakrishnan, Fausto Giacomet, Michal Chajdukowski and Laura-May Jones on May 17, 2024
Posted In United Kingdom
On 30 April 2024, the FCA and the PRA published their respective policy statements (PS24/4 [1] by the FCA and PS7/24[2] by the PRA) in response to feedback received on their proposed draft rules on securitisations, which were presented in 2023 (CP23/17[3] and CP15/23[4]). The new UK securitisation framework seeks to repeal and replace retained EU law in the...
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European Union Criminalizes Violations of Sanctions
By Sabine Naugès, Raminta Dereskeviciute and Michal Chajdukowski on May 2, 2024
Posted In Sanctions & Export Control
As announced in our last Quarterly Sanctions Update, on April 12, 2024 the Council of the European Union adopted a directive criminalizing sanctions violation at the European Union (EU) level. In this post, we provide a summary of the key provisions of this directive, to be followed by a second post focusing on its potential...
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