From the largest-ever sanctions packages issued in relation to Russia and new rules to tackle sanctions evasion, Lexology PRO explores the recent sanctions activity to identify key risks and trends for businesses.
This series will cover the following work areas for the period November 2023 to November 2024: data protection, anti-bribery and corruption (ABC) and anti-money laundering (AML), banking, and sanctions.
Scanner, our automated regulatory monitoring tool covers 14 regulatory areas and tracks over 1200 regulatory sources. We have published over 33,000 updates between November 2023 and November 2024.
Please note that the data in this article is based on Scanner’s regulatory coverage, full details of which can be found here.
Russia sanctions
US authorities were the most active in issuing sanctions overall, with the majority focused on Russia. On 23 February 2024, the US government announced its largest round of sanctions against Russia since the 2022 invasion of Ukraine. The sanctions package targeted over 500 entities and individuals in Russia’s financial, energy, and military sectors.
Swiss authorities were also fairly active in issuing sanctions, primarily targeting Russia. On 16 October 2024, the Swiss Federal Council adopted most of the outstanding measures from the EU’s 14th sanctions package, focusing on export controls, financial services, and maritime regulations. However, the government did not implement EU-equivalent measures related to foreign subsidiaries of Swiss companies.
The European Council was also among the more active regulators in enforcing sanctions against Russia. On 24 June 2024, the European Council adopted its 14th sanction package against Russia, covering 116 individuals and entities. The package expanded sanctions across the energy, finance, and trade sectors, including a ban on liquefied natural gas projects.
The UK continued to issue sanctions against Russia, with notable sanctions issued in June 2024 targeting President Putin’s “shadow fleet”, and further sanctions to target Putin’s “war machine” in November 2024. The UK has also launched its new trade sanctions agency, the Office of Trade Sanctions Implementation, which oversees the enforcement of trade sanctions.
Meanwhile, in Canada, the government announced its largest expansion of the sanctions list to date against Russia on 21 February 2024, involving 153 entities and 10 individuals. The government also introduced two potentially far-reaching sanctions measures to ban the acquisition or import of diamond-related products from Russia.
Iran sanctions
The US government also maintained its sanction regime against Iran. On 18 September 2024, President Joe Biden signed into law H.R.815, which included expansive new sanctions on Iran’s petroleum products, missile production, and foreign financial institutions facilitating Iranian oil and drone sales. The measures also expanded foreign direct product rules to certain items exported to Iran.
On 18 November 2024, the European Council widened its sanctions against Iran for supporting Russia’s invasion of Ukraine. The decision bans the export, transfer, supply, or sale from the EU to Iran of components used in developing and producing missiles and unmanned aerial vehicles.
New rules for sanctions violation and evasion
On 19 May 2024, new rules criminalising the violation of EU sanctions entered into force. Activities involving sanctioned entities or individuals, such as providing funds or economic resources, failing to freeze their funds or resources, or entering transactions with them, are punishable offences under the new rules.
EU authorities also adopted sanction rules relating to human rights, such as human trafficking. On 23 January 2024, the European Parliament agreed to add forced marriage, illegal adoption, and surrogacy-related exploitation under the EU’s anti-trafficking law. Those involved in such offences can face sanctions, including exclusion from public funding, like tender procedures, grants, concessions and licenses.
The US also published rules and amending regulations related to sanctions. Notably, the US government doubled the statute of limitations for violations of most US sanctions programmes on 24 April 2024. The statute limitations extend from five to ten years and apply to economic and financial sanctions, affecting both current and future national security programmes based on existing laws.