Czech government adds to national sanctions list
The Czech government has placed the head of the Russian Orthodox Church, Patriarch Kirill, on its national sanctions list for supporting Russia's invasion of Ukraine.
Kirill’s inclusion on the list means that any assets he has in Czechia will be frozen, he is barred from entering the country and cannot undertake any financial transactions here. Patriarch Kirill is the first name to appear on the Czech sanctions list after the government passed its own version of the US Magnitsky Act last year.
European Union: Expanding the list of Belarusian individuals and companies subject to sanctions
Council Implementing Regulation (EU) 2025/631 implementing Article 8a(1) of Regulation (EC) No. 765/2006 concerning restrictive measures in view of the situation in Belarus and Belarus' participation in Russia's aggression against Ukraine has been released. The regulation amends Annex I to Regulation (EC) No. 765/2006 concerning restrictive measures against Belarus. The list adds 25 natural persons and 7 legal entities related to the situation in Belarus and its participation in Russia's aggression against Ukraine. The regulation enters into force on March 27, 2025. Link
EU amends common position on military export controls
The EU has amended Article 2 of the Council’s Common Position 2008/944/CFSP on military export controls through Council Decision (CFSP) 2025/779. The Common Decision expands on the criteria set out in Article 2 of the Common Position, which EU Member States must apply when assessing applications for export licenses on military items. Link
SECO: Ordinance on measures against Belarus
On 4 April 2025 the Federal Department of Economic Affairs EAER has amended annex 13 of the Ordinance on measures against Belarus. Eleven individuals and two entities have been modified and one individual has been deleted. The measures come into force on 8 April 2025. Link
SECO: Ordinance on measures against Belarus
On 10 April 2025 the Federal Department of Economic Affairs EAER has amended annex 13 of the Ordinance on measures against Belarus. 25 individuals and seven entities have been modified. The measures come into force on 11 April 2025. Link
Spain Approves Draft Bill Transposing EU Directive on the Criminalization of Sanctions Violations
The Spanish Council of Ministers approved a draft bill to implement Directive (EU) 2024/1226 on the definition of criminal offenses and penalties for the violation of Union restrictive measures and amending Directive (EU) 2018/1673. The Directive established minimum Member State requirements concerning the definition of criminal offenses and penalties for the violation and circumvention of EU sanctions.
Spanish law does not currently have specific provisions criminalizing violations of EU sanctions. Instead, violations of certain EU sanctions measures are covered by more generic criminal or civil offenses, such as smuggling or money laundering. This creates complexity in sanctions enforcement because offenses derive from different legal instruments, these generic offenses are not defined, and do not currently provide for liability for all possible violations of EU sanctions.
Member States have until May 20, 2025, to transpose the Directive into national law. The Draft Bill is under public consultation until April 9, 2025 and its final text will need to be approved by the Spanish legislative chambers, entering into force 20 days after its official publication as organic law.
Switzerland amends Ordinance on Measures against the Islamic Republic of Iran
On 2 April the Federal Council decided to amend the Ordinance on Measures against the Islamic Republic of Iran. The measures will enter into force on 3 April. Link
UK: update to open general export licence
The open general export licence oil and gas exploration: dual-use items - from September 2022 has been revoked as it is no longer required.
UK publishes legal services threat assessment report for financial sanctions
OFSI has published a Legal Services Threat Assessment Report relating to UK financial sanctions. The report reaches several “key judgments” on threats to sanctions compliance that are relevant to the UK legal services industry:
- It is highly likely that UK trust and company services providers (TCSPs) have not self-disclosed all suspected breaches to OFSI.
- It is almost certain that most non-compliance by UK legal services providers has occurred due to breaches of OFSI licence conditions.
- It is almost certain that complex corporate structures, including trusts, linked to Russian DPs and their family members have obfuscated the ownership and control of assets which could be frozen under UK financial sanctions.
It is likely that Russian DPs have transferred the ownership and control of assets to non-designated individuals and entities. In some cases, this could breach UK financial sanctions.