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
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Quarterly Sanctions Update | Q2 2024

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 those relating to transfer of IP rights, or divestment. The list of restricted goods has also been significantly expanded and additional persons and entities have been added to the list of sanctioned persons.

On June 29, 2024, the EU also expanded its sanctions against Belarus in order to align with the goals of the 14th sanctions package. Additional sanctions under the Hamas and Palestinian Islamic Jihad and Sudan regimes were also published.

In this Quarterly Sanctions Update, we summarise the most recent and significant amendments introduced, or proposed, by the EU and the United Kingdom between April and July 2024.

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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 [...]

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