Europe Russia

Sanctions circumvention: EU-based companies at the heart of emerging risks

A recent Lithuanian report highlights a concerning evolution in the mechanisms used to circumvent sanctions targeting Russia. According to the findings, companies registered within the European Union, particularly in Lithuania, have been used to facilitate access to Western technologies through networks linked to Russia. The report notably refers to a company based in Vilnius that […]

Export control regulations Russia

Customs Codes and Russia Sanctions: Automating a Now Essential Compliance Check

Under the European sanctions against Russia, Regulation 833/2014 relies heavily on lists of products identified by their customs codes (HS codes). These codes have become a central component of export controls: they determine whether a product is prohibited, restricted, or subject to authorization. With the gradual expansion of sanctions, the scope of controls is no […]

Russia USA

OFAC General License 13P: Limited Authorization for Transactions with Russia

On January 6, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License 13P (GL 13P), introducing a temporary authorization for certain transactions that are otherwise prohibited under Directive 4 of Executive Order 14024. This development reflects the continued evolution of U.S. sanctions policy toward Russia, balancing restrictive measures with […]

Russia

Sanctions contre la Russie : l’OFAC inflige une amende record de 7,1 millions de dollars

Une sanction emblématique du durcissement américain L’Office of Foreign Assets Control (OFAC), rattaché au Trésor américain, a infligé une amende civile de 7,1 millions de dollars à la société Gracetown Inc., basée à New York, pour violations des sanctions visant l’oligarque russe Oleg Deripaska, inscrit sur la liste SDN depuis avril 2018. Cette affaire illustre […]

Russia

Russia–Hungary: energy continuity highlights divisions within the EU

In late November, energy relations between Hungary and Russia once again underscored internal divisions within the European Union regarding sanctions and energy security. On November 28, Hungarian Prime Minister Viktor Orbán travelled to Moscow to meet Russian President Vladimir Putin, with discussions focusing on Hungary’s energy supply and the situation in Ukraine. Following the meeting, […]

Russia

United Kingdom: record fine imposed for breach of Russia sanctions

In May 2025, UK authorities imposed the largest financial penalty ever issued under the United Kingdom’s sanctions regime targeting Russia. A UK-based exporter was fined £1,160,725.67 for unlawfully making goods available to Russia in breach of the sanctions regulations introduced in 2019. This case reflects the United Kingdom’s increasingly robust enforcement approach since 2022. In […]

Europe Russia

Export Control: Looking Back at a Major Arrest in Poland

In November 2024, Polish authorities took a significant step in the enforcement of European sanctions against Russia. At the time, Poland’s Internal Security Agency (ABW) arrested a German national accused of illegally exporting dual-use machinery to Russia, in breach of existing export control regulations. The equipment involved, originally intended for civilian industrial applications, was allegedly […]

Russia

Russia and Belarus sanctions: how to secure product exportability

In a global trade environment shaped by expanding sanctions against Russia and Belarus, as well as the rise of circumvention countries, one key question has become unavoidable for exporters: can your products legally reach their final destination?The growing complexity of sanctions regimes and shifting trade routes significantly increase export compliance risks. Consider three examples of […]

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