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Articles by Stephan Johansen
New U.S. Sanctions Targeting Russia And Iran And U.S. Tariffs Targeting Third Countries Buying Russian Energy
] The U.S. adds to its Russian sanctions and Iranian capabilities with the "Lindsey O. Graham Sanctioning Russia and Iran Act of 2026. In a long-awaited move by many, on Friday, 18 September 2026, President Donald Trump signed the "Lindsey O. Graham Sanctioning Russia and Iran Act of 2026" ("the Act") into law. While the real effects of the Act remain to be seen, it further broadens the authority of the President to impose sanctions against actors that deal with Russia and Iran.
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.
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.
EU’s 20th Sanctions Package on Russia
On 23 April 2026, the EU adopted its 20th package of sanctions against Russia. These measures are contained in (i) Council Regulation (EU) 2026/506 (see here), (ii) Council Implementing Regulation (EU) 2026/509 (see here), and (iii) Council Regulation (EU) 2026/511 (see here), as published in the Official Journal of the EU.
Getting the deal done: antitrust tips to push a transaction through effectively
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1. Think ahead • Which countries are the parties active in? • Is there a change of control? (Minority investments can trigger filing requirements in certain circumstances.) • How large is the turnover of the parties? (Transaction values, asset values and/or market shares may also trigger filings.) • Beware! Under competition law, turnover may include revenues not considered turnover under accounting rules. 2.
By Michelle A. Mantine, Courtney Bedell Averbach, Daniel Booker, Christopher Brennan, Christian Filippitsch, Marjorie Holmes, Edward Schwartz, William J. Sheridan, Natasha Tardif, Gregory Vose, Michaela Westrup, Max Seuster, Rafael Szmid, Emma Weeden, Vaibhav Adlakha, Caitlyn M. Holsopple, Leah Hungerman, Stephan Johansen, Nicole Kaplan, Michalis Papachristodoulou, Alexandre Shamloo, Jay Simmons
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reedsmith.com
EU LNG and Pipeline Gas Import Ban - Timing under EU Sanctions (Article 3ra) vs RePowerEU
As a follow-up to our previous client alerts on the EU’s Russian gas phase-out (available here), we have prepared an infographic summarising how the EU sanctions framework (Regulation 833/2014) interacts with the RePowerEU phase-out Regulation (Regulation 2026/261), including the key contract cut-off and phase-out dates for both LNG and pipeline gas.
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.
Pennsylvania legislators propose “baby HSR” law that would bring greater deal scrutiny and risk to health care merger activity in the state
Pennsylvania joins a growing number of states with legislators seeking to enact premerger notification laws modeled after the federal Hart-Scott-Rodino (HSR) Act. Under the HSR Act, parties to proposed transactions that meet certain thresholds must submit notification to the Federal Trade Commission (FTC) and Department of Justice (DOJ and, together with the FTC, the Agencies) and observe a 30-day waiting period before closing.
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.
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.
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.
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.
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).
Department of Justice secures first “victory” in criminal prosecution of no-poach and wage fixing agreements - key takeaways and what’s next | JD Supra
December 8, 2022 Courtney Bedell Averbach, Betty Graumlich, Stephan Johansen, Nicole Kaplan, Michelle Mantine, Danielle Stewart Reed Smith + Follow x Following x Following - Unfollow Contact To embed, copy and paste the code into your website or blog: After years of warnings and recent trial losses, the antitrust agencies continue to aggressively pursue antitrust violations in labor markets.
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