On 9 April 2026, the UK Office of Trade Sanctions Implementation (OTSI) announced that, from 27 April 2026, it will assume responsibility for licensing the export of sanctioned goods (and associated ancillary services) to sanctioned destinations (see here). Such
Sanctions & Export Controls Update
The Sanctions & Export Controls Update blog, published by Baker McKenzie, focuses on legal developments and regulatory changes related to international sanctions and export control regimes. It covers topics such as updates on sanctions imposed by governments and international bodies, compliance requirements for businesses, enforcement actions, licensing procedures, and the impact of sanctions on cross-border trade and transactions. The blog also addresses specific country sanctions, dual-use goods regulations, and coordinated international sanctions efforts, providing insights relevant to multinational corporations, legal practitioners, and compliance professionals navigating complex sanctions landscapes.
Latest from Sanctions & Export Controls Update - Page 9
Swiss Federal Supreme Court Decision 4A_454/2025 (the PostFinance Decision) from a Sanctions Perspective: No Free Pass for Sanctioned Parties!
On 3 March 2026, the Swiss Federal Supreme Court delivered a notable decision addressing the interplay between foreign sanctions regimes and Swiss law relating to the mandate of Swiss bank PostFinance to ensure access to basic payment services under Swiss…
OFAC Continues Relaxation of Sanctions On Venezuela’s Mineral Sector and Issues New Guidance About Secondary Sanctions Risks for Non-US Persons Engaging in Venezuela Transactions
On March 27, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) significantly expanded the scope of authorizations available for the Venezuelan minerals sector by amending an existing general license and issuing two new general licenses…
UK Supreme Court confirms broad reading of key aspect of UK sanctions (provision of financial services and funds for trade in prohibited goods)
On 25 March 2026, the UK Supreme Court issued an important judgment in the case of UniCredit Bank GmbH, London Branch v Constitution Aircraft Leasing (Ireland) / Celestial Aviation Services Ltd [2026] UKSC 10, confirming that a key aspect of…
DOJ National Security Division Issues Guidance on Voluntary Self-Disclosures Under the New Department-Wide Corporate Enforcement Policy
On March 30, 2026, the US Department of Justice (“DOJ”) National Security Division (“NSD”) announced updated guidance clarifying how companies should report voluntary self-disclosures (“VSDs”) of potential criminal violations of US national security laws, including export controls and sanctions, under…
OFAC Issues Iran-Related General License Authorizing Delivery and Sale of Iranian-Origin Crude Oil and Petroleum Products, and Amends Russia-Related General License 134
On March 20, 2026, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Iran-related General License U (“GL U”), “Authorizing the Delivery and Sale of Crude Oil and Petroleum Products of Iranian-Origin Loaded on Vessels as of…
OFAC Issues Amended and New General Licenses Tied to the Venezuelan Energy Sector
On March 13, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) expanded the scope of three existing general licenses (“GLs”) and issued two amended Frequently Asked Questions (“FAQs”) related to certain imports and activities involving…
EU issues new FAQ guidance on the provision of payments services under the EU Russia Sanctions
On 13 March 2026, the European Commission published a new set of Frequently Asked Questions (“FAQs”, accessible here) clarifying the scope and application of EU sanctions restrictions on the provision of payment services under Article 5b(2) of Council Regulation…
UK Government publishes policy paper on its approach to sanctions enforcement
On 10 March 2026, the UK Government published a policy paper outlining the UK’s approach to enforcing sanctions breaches (available here). The policy paper sets out that “[r]obust enforcement of UK sanctions is a priority for this government”. The…
Temporary OFAC General Licenses Authorize Transactions Involving Russian Origin Crude Oil and Petroleum
Following the Trump Administration’s removal of tariffs on products of India for “buying Russian oil” in February, the Office of Foreign Assets Control (“OFAC”) has issued a temporary general license to authorize transactions that are “ordinarily incident and necessary to…