Unpacking the Implications of the EU’s 11th Sanctions Package: The Expected (and Unexpected) Compliance Aftermath
Nicholas Richards-Bentley
Head Legal Trade/Sanctions
Novartis (Switzerland)
Aline Doussin
Partner
Hogan Lovells LLP (France)
- Leveraging new tools to combat circumvention, including designation of “high risk third countries”
- Understanding how the new anti-circumvention provisions will affect compliance programs through added due diligence of secondary sales and end-use in Russia
- Practical impact of restrictions on vessels entering EU ports in an effort to avoid ship-to-ship transfers of Russian oil
- Exploring the prohibition of intellectual property rights sales in connection with already restricted products