Why do Policymakers Love Complex Sanctions?

Now that we have seen the EU’s adoption of a slimmed down 10th sanctions package on Russia after months of ambitious discussion of imposing new costs, it makes sense for us in the compliance community to step back and take a wider view of why politicians and officials increasingly impose complicated sanctions measures and whatContinue reading “Why do Policymakers Love Complex Sanctions?”

Takeaways from the Process for the 10th Sanctions Package 

Today marks the one year anniversary of Russia’s invasion of Ukraine, and we are still awaiting the EU’s long signaled 10th sanctions package, which was pledged to be a key statement of the resolve of the Union and further demonstration of the effort to hinder Russia’s ability to wage aggression. Pegged by some just lastContinue reading “Takeaways from the Process for the 10th Sanctions Package “

Will Europe Target Privileged Industries in the 10th Sanctions Package?

Pushed by hawkish member states of Poland and the Baltic states, the EU has begun working on the 10th sanctions package with an expectation that it will be ready to enact in time for the one year anniversary of Russia’s invasion of Ukraine on 24 February. The discussions yet again mention banning the import ofContinue reading “Will Europe Target Privileged Industries in the 10th Sanctions Package?”

Russian Oil Product Price Cap – What will it look like?

On 30 December 2022, US Treasury’s OFAC quietly released their preliminary guidance for the forthcoming price cap for the provision of services related to the maritime transport of Russian oil products. The cap is scheduled to be implemented by 5 February 2023 by the EU, G7 members and Australia. Much as with the crude oilContinue reading “Russian Oil Product Price Cap – What will it look like?”

Key Takeaways from OFAC Settlement Agreement with Danfoss A/S

On 30 December 2022, US Treasury’s OFAC announced its settlement with Danish company Danfoss A/S for causing US financial institutions to violate US sanctions on Iran, Syria and Sudan. The settlement was for over $4 million which was negotiated down from a statutory maximum of almost $22 million as a result of Danfoss’ extensive cooperationContinue reading “Key Takeaways from OFAC Settlement Agreement with Danfoss A/S”

What do Nordic political changes mean for the  future of sanctions on Russia and beyond?

 At a time of acute economic and security challenges, when there seemed to be a whipsaw of leadership changes all across Europe, the same had not held quite as true in the Nordics. As we are now in the fluid period of government formation in Denmark, with the effort being led by the same  official,Continue reading “What do Nordic political changes mean for the  future of sanctions on Russia and beyond?”

Key Takeaways for Senior Management and Compliance Personnel from the Dan Bunkering Verdict

The verdict against Dan Bunkering, Bunker Holding, as well as the chairman of Dan Bunkering and CEO of Bunker Holding, is monumental not only because it is a rare example of a criminal conviction for EU sanctions compliance failures, but because it confirms the scope and expectations for what it means to comply with EUContinue reading “Key Takeaways for Senior Management and Compliance Personnel from the Dan Bunkering Verdict”