Unpacking the Implications of the EU’s 11th Sanctions Package: The Expected (and Unexpected) Compliance Aftermath

November 16, 2023 2:15pm

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