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Articles by James Willn
The revocation of General License X: Lessons for a changing sanctions environment
The Office of Foreign Assets Control’s (OFAC) issuance of General License X (GL X) on 22 June 2026 temporarily authorised the production, delivery, and sale of crude oil, petroleum, and petrochemical products of Iranian origin until 21 August 2026. This significant development followed reports of a US-Iran memorandum of understanding (MoU), whereby the US would agree to issue waivers for those Iranian products listed, alongside associated services including insurance, banking, and transportation.
UK sanctions update: new Russia package targets LNG shadow fleet, propagandists, and human rights abusers
On 1 October 2026, the UK government announced a significant new package of 31 sanctions against Russia. The package comprises 23 new designations of individuals and entities and eight ship specifications, representing a further intensification of the UK’s economic pressure on Russia ahead of winter.
UK sanctions update: new Russia package targets LNG shadow fleet, propagandists, and human rights abusers
On 1 October 2026, the UK government announced a significant new package of 31 sanctions against Russia. The package comprises 23 new designations of individuals and entities and eight ship specifications, representing a further intensification of the UK’s economic pressure on Russia ahead of winter.
UK sanctions update: new Russia package targets LNG shadow fleet, propagandists, and human rights abusers
On 1 October 2026, the UK government announced a significant new package of 31 sanctions against Russia. The package comprises 23 new designations of individuals and entities and eight ship specifications, representing a further intensification of the UK’s economic pressure on Russia ahead of winter.
U.S. sanctions update – Syria SST rescission, Operation Economic Outcast, and Iran sanctions developments
On 24 August 2026, the United States took coordinated action across its Syria and Iran sanctions programmes. Secretary of State Marco Rubio rescinded Syria’s State Sponsor of Terrorism (SST) designation after the 45-day Congressional notification period, and Hay’at Tahrir al-Sham (HTS) was delisted as a Specially Designated Global Terrorist (SDGT) organisation and removed from the Specially Designated Nationals and Blocked Persons (SDN) List.
EU’s 21st Sanctions Package: Banks, Barrels, and a Bigger Blacklist
The Council adopted its 21st package of restrictive measures against Russia on 23 July 2026. The instruments entered into force on 24 July 2026 (the day following publication in the Official Journal). The principal instruments are Regulation (EU) 2026/1848; Regulation (EU) 2026/1844; and Implementing Regulation (EU) 2026/1843 (amending and implementing Regulation (EU) No 269/2014). Executive summary A notification duty applies to any EU-linked sale of an LNG tanker to a third country.
OFAC Revokes Iran General License X: Only a Short Wind-Down Remains
On July 7, 2026, OFAC revoked Iran General License X (GL X) and replaced it with General License X1 (GL X1). The waiver, which had been due to run until August 21, lasted barely two weeks. GL X1 is not a continuation; it is a narrow wind-down authorization that expires on July 17, 2026. Three tankers were attacked in the Strait of Hormuz on July 7 and Washington pulled GL X immediately, a warning of the consequences for Iran’s alleged actions in the strait.
OFAC Revokes Iran General License X: Only a Short Wind-Down Remains
On July 7, 2026, OFAC revoked Iran General License X (GL X) and replaced it with General License X1 (GL X1). The waiver, which had been due to run until August 21, lasted barely two weeks. GL X1 is not a continuation; it is a narrow wind-down authorization that expires on July 17, 2026. Three tankers were attacked in the Strait of Hormuz on July 7 and Washington pulled GL X immediately, a warning of the consequences for Iran’s alleged actions in the strait.
OFAC general licence - Iranian-origin petroleum products
On 21 June 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License X (“GL X”), authorising certain transactions relating to the production, sale, delivery and offloading of Iranian-origin crude oil, petrochemical products and petroleum products. This represents a remarkable — if temporary — departure from the comprehensive United States sanctions framework that has constrained Iranian energy trade for decades.
Investigations and enforcement trends: Top takeaways for Q2 2026
We recently gathered a group of regulatory attorneys from across Reed Smith to provide a rundown of the key trends to watch for in Q2 2026. If you missed the webinar, you can access the recording on demand.
UK imposes new Russia sanctions - mirroring of EU position on the maritime transport of LNG and refined petroleum products derived from Russian crude
Ban on the import of CN 2710 products derived from Russian crude and refined in third countries – subject to diesel and jet fuel exceptions. Prohibition on the maritime transportation of Russian LNG – subject to carve-outs for: (i) pre-existing long-term LNG contracts until 1 January 2027; and (ii) Sakhalin and Yamal 2 projects. Expansion of specified “shadow-fleet” vessel restrictions, with wide-ranging measures prohibiting provision of all principal services to specified ships.
UK issues General Trade Licence for import of diesel and jet fuel derived from Russian crude oil
On 19 May 2026, the Department for Business and Trade (DBT) issued General Trade Licence GBSAN0004 (the Licence), authorising the import into the United Kingdom of certain processed oil products derived from Russian crude oil. The Licence, which comes into force on 20 May 2026, marks a notable relaxation of the UK’s otherwise comprehensive sanctions regime targeting Russian energy products.
Gulf conflict: Challenges affecting businesses in the energy sector
12 March 2026 / 1 min read / Reed Smith Client Alerts Authors Kyri Evagora, Simone Goligorsky, Brett Hillis, James Willn, Antonia Birt, Sally-Ann Underhill, Mark Pring, Elizabeth Farrell, Nick Moon Authors Key takeaways The Gulf conflict is placing stress upon energy assets and the logistics and insurance infrastructure upon which energy supply chains depend The Strait of Hormuz is a structural choke point carrying approximately 20-25% of global oil and LNG supplies in 2025 Near-term...
EU 14th sanctions package introduces restrictions on Russian LNG
Key takeaways Those involved in activities relating to Russian LNG that enters EU territory should seek advice on the impacts of the new restrictions on the performance of their contracts. Russian LNG remains permitted to be imported into the EU via LNG terminals that are connected to the interconnected natural gas network. We summarised the other sanctions restrictions introduced by the 14th sanctions package here.
Abu Dhabi court weighs in on Dubai Decree No. 34 of 2021
Key takeaways Abu Dhabi Court holds that abolishment of the DIFC-LCIA arbitration centre does not lead to unenforceability of arbitration agreements that refer to the DIFC-LCIA. UAE courts’ practice is shifting to a broader, arbitration-friendly interpretation of arbitration agreements. Arbitration is becoming “prevailing norm” to resolve commercial disputes in UAE.
Key sanctions cases and trends in England: Is your sanctions clause robust?
Key takeaways 2020 to 2023 unsurprisingly saw an uptick in sanctions-related disputes and cases before the English courts and many of these cases have set precedents for various conceptual issues under English law. These precedents could have a profound impact on businesses and their existing contracts. This update follows our recent client alert highlighting some of these key cases and trends.
OFAC issues wind-down license for Venezuelan oil
On October 15, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License 44, “Authorizing Transactions Related to Oil or Gas Sector Operations in Venezuela,” which temporarily authorized transactions related to oil and gas sector operations, including transactions involving PdVSA. This was described in the Reed Smith update, which may be found here.
OFAC issues wind-down license for Venezuelan oil
On October 15, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License 44, “Authorizing Transactions Related to Oil or Gas Sector Operations in Venezuela,” which temporarily authorized transactions related to oil and gas sector operations, including transactions involving PdVSA. This was described in the Reed Smith update, which may be found here.
Navigating the impact of sanctions on commercial contracts: an overview of key cases and trends in England and Singapore
Key takeaways The courts in England and Singapore are continuing to resolve a stream of disputes arising out of an ever-evolving sanctions landscape. This article reviews recent reported cases in which the courts have tackled the impact of sanctions on commercial contracts, whether through the interpretation of sanctions laws or sanctions clauses in contracts.
EU Clarifies Article 3q for Tanker S&P Market
In a previous update posted on our Trade Compliance Resource Hub on 13 February 2024 (The 12th package of EU sanctions against Russia: impact on the tanker S&P market), we explored the introduction of Article 3q restrictions on tanker sales as part of the EU’s 12th package of sanctions against Russia. In that update, we flagged a number of ambiguities over how Article 3q may be interpreted.
EU Clarifies Article 3q for Tanker S&P Market
In a previous update posted on our Trade Compliance Resource Hub on 13 February 2024 (The 12th package of EU sanctions against Russia: impact on the tanker S&P market), we explored the introduction of Article 3q restrictions on tanker sales as part of the EU’s 12th package of sanctions against Russia. In that update, we flagged a number of ambiguities over how Article 3q may be interpreted.
Greener Arbitrations | Are in-person hearings worth their while?
Click here to listen to the audio In this next episode of our Greener Arbitrations miniseries, James Willn, Ana Ulseth, Chris Edwards and Mathilde Adant debate the environmental impact of in-person vs. remote hearings. Hosts Alison Eslick and Vanessa Thieffry moderate the session in which debaters discuss technological issues, security challenges and the financial and psychological impacts of remote hearings.
Christmas comes early for G7 operators - EU adopts 12th package of sanctions against Russia, changes to the Price Cap Model
On 18 December, the EU announced their 12th round of sanctions targeting Russia. This comes against the backdrop of a flurry of Russia sanctions related activity; namely, widely reported price cap investigations by the G7; release of the U.S., updated quint-seal guidance on maritime sanctions compliance; and a number of designations of third country actors believed to be engaged in price-cap circumvention.
Christmas comes early for G7 operators - EU adopts 12th package of sanctions against Russia, changes to the Price Cap Model
On 18 December, the EU announced their 12th round of sanctions targeting Russia. This comes against the backdrop of a flurry of Russia sanctions related activity; namely, widely reported price cap investigations by the G7; release of the U.S., updated quint-seal guidance on maritime sanctions compliance; and a number of designations of third country actors believed to be engaged in price-cap circumvention.
Shipping briefing: Drill, baby, drill? A new Venezuelan wave for the shipping industry
After many rumors of potential changes to the U.S. policy on Venezuela, on October 18, 2023 the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued four general licenses, representing a significant shift in its Venezuela sanctions program. Most pertinent for the shipping industry, certain sanctions that were in place against Petróleos de Venezuela, S.A. (PdVSA) and the Venezuela oil, gas and mining sectors have now largely been relaxed.
UK Sanctions - What is “Control”?
The recent English Court of Appeal judgment on Mints & others v PJSC National Bank Trust & PJSC Bank Otkritie Financial Corporation [2023] EWCA Civ 1132 (“Mints”) on 6 October 2023 discussed several fundamental issues pertaining to concepts under the Sanctions and Anti-Money Laundering Act 2018 (“SAMLA”) and the secondary sanctions regulations thereunder, in particular the Russia (Sanctions) (EU Exit) Regulations 2019 (the “Regulations”). The judgment can be found here.
UK Sanctions - What is “Control”?
The recent English Court of Appeal judgment on Mints & others v PJSC National Bank Trust & PJSC Bank Otkritie Financial Corporation [2023] EWCA Civ 1132 (“Mints”) on 6 October 2023 discussed several fundamental issues pertaining to concepts under the Sanctions and Anti-Money Laundering Act 2018 (“SAMLA”) and the secondary sanctions regulations thereunder, in particular the Russia (Sanctions) (EU Exit) Regulations 2019 (the “Regulations”). The judgment can be found here.
A little less conversation, more action
October 12, 2023, witnessed perhaps one of the most fast-paced days since the introduction of the price cap restrictions on Russian crude oil and petroleum products almost a year ago. Namely, the G7 and Australia (the “Price Cap Coalition”) issued a joint statement, which was followed by the issuance of a maritime advisory and the first sanctions imposed by the Office of Foreign Assets Control (“OFAC”) for breach of the Russian oil price cap.
Further UK and EU sanctions on Russian iron and steel come into effect
On Saturday (September 30, 2023), new UK and EU trade sanctions tightening the restrictions on the import of Russian-origin iron and steel products will come into effect.
EU FAQs - STS in EU Territorial Waters
On 2 August 2023 evening, the EU Commission released new FAQs (here and here; word search “2 August 2023”). Of greatest interest are the two new FAQs in the “Oil Import” section, relating to STS activity relating to Russian oil and petroleum products, in EU territorial waters. We set out extracts of these two below. In short, these FAQs state that STS activity relating to Russian oil or petroleum products in EU territorial waters are prohibited under Article 3m of Regulation 833/2014 (as amended).
New restrictions on legal advisory services - what do you need to know?
After the United Kingdom imposed new restrictions on legal advisory services on 30 June 2023, it is becoming increasingly more complicated for organizations to gauge what kinds of legal advice they are able to provide with respect to Russia. As these restrictions apply to in house legal and compliance functions as well as law firms, it is important to know where these lines are drawn for the various sanctions regimes.
EU Clarifies Article 3eb and 3ec port ban restrictions
On 24 July 2023, the EU Commission published updated FAQs (here and here) relating to the port ban restrictions under Articles 3eb and 3ec of the EU’s 11th Sanctions Package (implemented on 23 June 2023). We published a brief summary on the 11th Sanctions Package which can be reviewed here. To recap, Articles 3eb and 3ec provide for the following: ‘Article 3eb 1.
EU 11th SANCTIONS PACKAGE - UPDATE
On 23 June 2023, the EU published its 11th sanctions package. We set out below a summary of key highlights in this latest update. These are all subject to further interpretative guidance provided by the EU, where applicable.
Sanctions Update - Belarus
On 9 June 2023, the UK implemented The Republic of Belarus (Sanctions) (EU Exit) (Amendment) Regulations 2023 which amends The Republic of Belarus (Sanctions) (EU Exit) Regulations 2019 (the “Belarus Regulations”). The latest approach allows the UK government to more strongly target exports from Belarus and to ramp up restrictions against Belarus to avoid any circumventions of restrictions against Russia via Belarus.
UK Sanctions - 18th Amendment
On 21 April 2023, the UK implemented The Russia (Sanctions) (EU Exit) (Amendment) Regulations 2023 (“18th Amendment”) which amends The Russia (Sanctions) (EU Exit) Regulations 2019 (“UK Russia Regulations”). This follows from the UK Government’s announcement on 24 February 2023 to, amongst other things, expand the list of products subject to restrictions on import into the UK, supply and delivery to non-UK countries and export restrictions. The announcement can be found on Gov.uk.
Russian petroleum product price cap implemented
Shortly before the 5 February 2023 cut-off date for the provision of maritime services related to the transportation of Russian petroleum products, the UK, EU and U.S. each published the relevant price cap for petroleum products falling under HS/CN Code 2710 that are of Russian origin or consigned or exported from Russia to non-G7 countries (Restricted Petroleum Products).
EU sanctions on Russia: The impact on Gulf-based EU companies
As the conflict in Ukraine continues, so does the response of the West, one of which is in the form of sanctions against Russia. Sanctions from the US, EU and UK continue to expand. In this week alone we are already discussing the implications of the G7 price cap on the purchase of Russian oil and how that will impact the energy market and wider ecosystem.
Latest UK Sanctions Against Russia – Oil Ban, Insurance, Gold, Coal And Business Services - Export Controls & Trade & Investment Sanctions - UK
On 21 July 2022, the UK's recent sanctions against Russia came into force. This latest round of sanctions impacts the oil, insurance, energy, gold and coal markets, as well as providing for certain restrictions on the provision of professional and business services to Russia. Whilst broadly looking to align themselves with existing EU sanctions, there are notable differences between how these UK sanctions will be applied which are now discussed within this update.
EU Sanctions - The Russian Crude Oil And Transport Insurance Restrictions Explained - Export Controls & Trade & Investment Sanctions - European Union
As we previously reported, on 3 June 2022 the EU adopted its sixth package of sanctions against Russia and Belarus. We know that there has been considerable confusion and widespread debate across the energy and maritime industries over how to interpret and comply with these recent sanctions. Our alert aims to shed some light on what the latest sanctions mean in practice and the direct impact they are likely to have on the day-to-day business of the companies affected.
US Sanctions - Who Do They Apply To And What Steps Can You Take? - International Law - United States
To print this article, all you need is to be registered or login on Mondaq.com. Under the Trump administration, the use of sanctions was a key US foreign-policy tool. Following the US presidential election on 3 November 2020, we explore the scope of the US sanctions regime and its applicability to individuals and entities and to what extent this will change under the President-elect Joe Biden. Introduction to US sanctions What is their purpose?
Key Measures Taken By Arbitral Institutions In Response To The COVID-19 Pandemic
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