As a customs, export control, and sanctions professional with over 20 years of experience, I’ve always maintained that the United States was the only jurisdiction in the world to impose formal secondary sanctions—those sanctions targeting third parties (non-US persons) for engaging in prohibited activities with sanctioned entities or countries. But this landscape is shifting, and I wanted to take this opportunity to share with you how the EU and UK have started to follow suit.
In this blog, I will discuss recent developments that have dramatically altered the way we understand secondary sanctions. I'll break down the EU and UK regulations amendments that effectively blur the lines between primary and secondary sanctions, giving non-EU and non-UK entities a lot more to consider when dealing with Russia. As an expert in this field, I’ll walk you through the intricate details of how these sanctions are evolving and what they mean for your compliance strategy moving forward.