Law360, Expert Analysis: This article is part of a quarterly column exploring recent developments in sanctions imposed on Russia by the UK, EU and US and the compliance implications. This instalment looks at the growing importance of UK trade sanctions in recent years, underscoring the rapidly evolving approach and expectations of agencies and regulators. Alexandra Melia, partner at Steptoe International (UK) LLP, examines His Majesty’s Revenue and Customs (HMRC)’s enforcement action against Petrofac, including its implications for UK trade sanctions compliance and the evolving approach to trade sanctions enforcement.

Law360: A court ruling on 10 April 2024, whichreverseed the first round of EU sanctions imposed on two Russian tycoons, contrasts with the approach taken by the English courts, where legal challenges to the restrictive measures have been repeatedly rebuffed.

Insert the following definitions as new definitions into clause 1 of Precedent: Asset purchase agreement—pro-buyer—corporate seller—conditional—long form: 1 Definitions and interpretation Sanctioned Activity • means any activity subject to sanctions imposed by the Sanctioning Body; Sanctioning Body • means the United Kingdom, United States of America, European Union and any other applicable local, national or multinational government agency, department, official parliament, public or statutory person or any government or professional body, regulatory or supervisory authority, board or other body responsible for imposing and/or administering sanctions; Sanctioned Entity • means any person or entity which is, or which is owned or controlled directly or indirectly by a person or entity which is, the subject of sanctions imposed by, or on a designated sanctions list by, a Sanctioning

Insert the following definitions as new definitions into clause 1 of Precedent: Asset purchase agreement—pro-buyer—corporate seller—unconditional—long form: 1 Definitions and interpretation Sanctioned Activity • means any activity subject to sanctions imposed by the Sanctioning Body; Sanctioning Body • means the United Kingdom, United States of America, European Union and any other applicable local, national or multinational government agency, department, official parliament, public or statutory person or any government or professional body, regulatory or supervisory authority, board or other body responsible for imposing and/or administering sanctions; Sanctioned Entity • means any person or entity which is, or which is owned or controlled directly or indirectly by a person or entity which is, the subject of sanctions imposed by, or on a designated sanctions list by, a Sanctioning

Insert the following definitions as new definitions into clause 1 of Precedent: Asset purchase agreement—pro-seller—corporate seller—conditional—long form: 1 Definitions and interpretation Sanctioned Activity • means any activity subject to sanctions imposed by the Sanctioning Body; Sanctioning Body • means the United Kingdom, United States of America, European Union and any other applicable local, national or multinational government agency, department, official parliament, public or statutory person or any government or professional body, regulatory or supervisory authority, board or other body responsible for imposing and/or administering sanctions; Sanctioned Entity • means any person or entity which is, or which is owned or controlled directly or indirectly by a person or entity which is, the subject of sanctions imposed by, or on a designated sanctions list by, a Sanctioning

Insert the following definitions as new definitions into clause 1 of Precedent: Asset purchase agreement—pro-seller—corporate seller—unconditional—long form: 1 Definitions and interpretation Sanctioned Activity • means any activity subject to sanctions imposed by the Sanctioning Body; Sanctioning Body • means the United Kingdom, United States of America, European Union and any other applicable local, national or multinational government agency, department, official parliament, public or statutory person or any government or professional body, regulatory or supervisory authority, board or other body responsible for imposing and/or administering sanctions; Sanctioned Entity • means any person or entity which is, or which is owned or controlled directly or indirectly by a person or entity which is, the subject of sanctions imposed by, or on a designated sanctions list by, a Sanctioning

Insert the following definitions as new definitions into clause 1 of Precedent: Asset purchase agreement—short form: 1 Definitions and interpretation Sanctioned Activity • means any activity subject to sanctions imposed by the Sanctioning Body; Sanctioning Body • means the United Kingdom, United States of America, European Union and any other applicable local, national or multinational government agency, department, official parliament, public or statutory person or any government or professional body, regulatory or supervisory authority, board or other body responsible for imposing and/or administering sanctions; Sanctioned Entity • means

Insert the following definitions as new definitions into clause 1 of Precedent: Share purchase agreement—pro-buyer—corporate seller—conditional—long form: 1 Definitions and interpretation Sanctioned Activity • means any activity subject to sanctions imposed by the Sanctioning Body; Sanctioning Body • means the United Kingdom, United States of America, European Union and any other applicable local, national or multinational government agency, department, official parliament, public or statutory person or any government or professional body, regulatory or supervisory authority, board or other body responsible for imposing and/or administering sanctions; Sanctioned Entity • means any person or entity which is, or which is owned or controlled directly or indirectly by a person or entity which is, the subject of sanctions imposed by, or on a designated sanctions list by, a Sanctioning

Insert the following definitions as new definitions into clause 1 of Precedent: Share purchase agreement—pro-buyer—corporate seller—short form. 1 Definitions and interpretation Sanctioned Activity • means any activity subject to sanctions imposed by the Sanctioning Body; Sanctioning Body • means the United Kingdom, United States of America, European Union and any other applicable local, national or multinational government agency, department, official parliament, public or statutory person or any government or professional body, regulatory or supervisory authority, board or other body responsible for imposing and/or administering sanctions; Sanctioned Entity • means any person or entity which is, or which is owned or controlled directly or indirectly by a person or entity which is, the subject of sanctions imposed by, or on a designated sanctions list by, a Sanctioning

Insert the following definitions as new definitions into clause 1 of Precedent: Share purchase agreement—pro-buyer—corporate seller—unconditional—long form: 1 Definitions and interpretation Sanctioned Activity • means any activity subject to sanctions imposed by the Sanctioning Body; Sanctioning Body • means the United Kingdom, United States of America, European Union and any other applicable local, national or multinational government agency, department, official parliament, public or statutory person or any government or professional body, regulatory or supervisory authority, board or other body responsible for imposing and/or administering sanctions; Sanctioned Entity • means any person or entity which is, or which is owned or controlled directly or indirectly by a person or entity which is, the subject of sanctions imposed by, or on a designated sanctions list by, a Sanctioning

Insert the following definitions as new definitions into clause 1 of Precedent: Share purchase agreement—pro-buyer—individual sellers—conditional—long form. 1 Definitions and interpretation Sanctioned Activity • means any activity subject to sanctions imposed by the Sanctioning Body; Sanctioning Body • means the United Kingdom, United States of America, European Union and any other applicable local, national or multinational government agency, department, official parliament, public or statutory person or any government or professional body, regulatory or supervisory authority, board or other body responsible for imposing and/or administering sanctions; Sanctioned Entity • means any person or

Insert the following definitions as new definitions into clause 1 of Precedent: Share purchase agreement—pro-buyer—individual sellers—short form: 1 Definitions and interpretation Sanctioned Activity • means any activity subject to sanctions imposed by the Sanctioning Body; Sanctioning Body • means the United Kingdom, United States of America, European Union and any other applicable local, national or multinational government agency, department, official parliament, public or statutory person or any government or professional body, regulatory or supervisory authority, board or other body responsible for imposing and/or administering sanctions; Sanctioned Entity • means any person