The Biden administration continued to escalate sanctions targeting Russia ahead of the change in presidential administration. President Trump has subsequently intervened actively on the international stage as regards the broader conflict in Ukraine. Since taking office, he has raised the possibility of both loosening the Russian sanctions regime and introducing more comprehensive sanctions. The future direction of travel is therefore highly uncertain.

At the same time, in the last nine months, the EU has further enhanced its sanctions against Russia through the adoption of its 14th, 15th, and 16th sanctions packages. In parallel, the U.K. has placed a renewed emphasis on its enforcement of trade sanctions, widening the scope of reporting requirements and clamping down on sanctions circumvention. In February 2025, it imposed its largest package yet, with over 100 new designations. This note looks into the latest sanctions requirements in the U.S., EU, and U.K. and their implications for businesses. These changes significantly alter the landscape for compliance. The situation remains highly dynamic. 

U.S. sanctions: continuing escalation and change in administration

Overview

In early 2025, under President Biden’s outgoing regime, the United States issued sweeping new rounds of sanctions targeting Russia, particularly the Russian petroleum sector and the broader energy sector, all of which still remain in place at the time of writing.

Energy sector sanctions

Executive Order 14024 (EO 14024) authorizes the imposition of blocking (i.e., freezing) sanctions on various categories of persons meeting the detailed criteria, including, as relevant here, on any person determined by the U.S. Secretary of the Treasury, in consultation with the U.S. Secretary of State, to operate or have operated in the technology sector, the defense and related material sector, or any other sector of the Russian Federation’s economy as determined by the U.S. Secretary of the Treasury (in consultation with the U.S. Secretary of State). Prior to January 10, 2025, 16 sectors of the Russian economy had been targeted under EO 14024.

On January 10, 2025, the U.S. Secretary of the Treasury issued a determination identifying the energy sector of the Russian Federation under EO 14024. Notably, this determination targeting the Russian energy sector mirrors a previously issued determination introduced in 2014 pursuant to Executive Order 13662 (EO 13662) as part of the Ukraine-/Russia-Related Sanctions program.

In connection with the new determination pursuant to EO 14024, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has stated in public guidance that it intends to publish regulations, defining the term “energy sector of the Russian Federation” to include “activities such as the procurement, exploration, extraction, drilling, mining, harvesting, production, refinement, liquefaction, gasification, regasification, conversion, enrichment, fabrication, manufacturing, testing, financing, distribution, purchase or transport to, from, or involving the Russian Federation, of petroleum, including crude oil, lease condensates, unfinished oils, natural gas, liquefied natural gas, natural gas liquids, or petroleum products, or other products capable of producing energy, such as coal, wood, or agricultural products used to manufacture biofuels; the development, production, testing, generation, transmission, financing, or exchange of power, through any means, including nuclear, electrical, thermal, and renewable, to, from, or involving the Russian Federation; and any related activities, including the provision or receipt of goods, services, or technology to, from, or involving the energy sector of the Russian Federation economy.” 

Any person identified by the U.S. Secretary of the Treasury, in consultation with the U.S. Secretary of State, as operating in the Russian energy sector may now be targeted with blocking (i.e., freezing) sanctions. U.S. persons¹ will be generally prohibited from engaging in any transactions or dealings with or for the benefit of any persons so targeted, and non-U.S. persons engaging in any such transactions or dealings will risk becoming sanctioned themselves.

Petroleum services sanctions

Executive Order 14071 (EO 14071) (concerning “new investment” in, and the provision of certain services to, Russia) prohibits the exportation, re-exportation, sale, or supply, directly or indirectly, from the United States or by a U.S. person (wherever located) of any category of services as determined by the U.S. Secretary of the Treasury (in consultation with the U.S. Secretary of State) to any person located in Russia.

On January 10, 2025, the U.S. Secretary of the Treasury issued a determination identifying “petroleum services” as a category of prohibited services under EO 14071.

 OFAC has stated in public guidance that it intends to publish regulations defining the term “petroleum services” for these purposes as “services related to the exploration, drilling, well completion, production, refining, processing, storage, maintenance, transportation, purchase, acquisition, testing, inspection, transfer, sale, trade, distribution, or marketing of petroleum, including crude oil and petroleum products, as well as any activities that contribute to Russia’s ability to develop its domestic petroleum resources, or the maintenance or expansion of Russia’s domestic production and refining. This would include services related to natural gas as a byproduct of oil production in Russia.”

Three types of service are specifically excluded: (i) petroleum services related to isotopes derived from petroleum manufacturing that are used for medical, agricultural, or environmental purposes; (ii) certain authorized services related to the maritime transport of crude oil and petroleum products of Russian origin (provided such products are purchased at or below relevant price caps); and (iii) services in connection with the wind down or divestiture of an entity located in Russia that is not owned or controlled, directly or indirectly, by a Russian person. OFAC has also issued a new general license which authorizes all otherwise prohibited transactions which relate to the Caspian Pipeline Consortium, Tengizchevroil, or Sakhalin-2 projects until June 28, 2025.

Subject to the above and unless otherwise authorized by OFAC, U.S. persons are now generally prohibited from, directly or indirectly, providing petroleum services to any person in Russia.

Additional sanctions designations

Since early 2022, OFAC has continued to target Russian individuals and entities with sanctions, as well as non-Russian entities targeted for engaging in transactions with or in support of the Russian defense sector or other targeted sectors of the Russian economy.

Concurrently with the new sanctions targeting the energy sector and petroleum services, and again on January 15, 2025, the U.S. imposed blocking (i.e., freezing) sanctions on dozens of persons engaged in Russia’s energy sector by identifying such persons on OFAC’s List of Specially Designated Nationals and Blocked Persons (the SDN List, and persons identified thereon, SDNs). It is noteworthy that many of these new sanctions designations were imposed pursuant to both EO 14024 and EO 13662 and, in many cases, OFAC re-designated previously sanctioned persons under EO 13662. Unlike EO 14024, EO 13662 is a covered authority pursuant to the Countering America’s Adversaries Through Sanctions Act (CAATSA). CAATSA mandates the imposition of sanctions in certain circumstances and includes: (i) mandated procedures for the removal of sanctions in some cases; and (ii) provisions for the legislative override of sanctions terminations. Consequently, the double designation of persons pursuant to EO 14024 and EO 13662 and/or re-designation of certain already sanctioned persons to add designation pursuant to EO 13662 may have the effect of making it more difficult for the Trump administration to unilaterally remove these sanctions.

Those targeted include a number of oil-carrying vessels, traders of Russian oil, and Russia-based oilfield service providers, as well as increased sanctions on two major Russian oil producers - PJSC Gazprom Neft and OJSC Surgutneftegas, and various of their respective subsidiaries and affiliates.

These sanctions generally prohibit (absent authorization from OFAC) transactions or dealings with a U.S. nexus (i.e., any U.S. persons or conduct occurring from, through, or within the United States) in or involving: (i) such SDNs or any entities in which such SDNs own an interest of 50% or more (directly or indirectly, individually or in the aggregate) (such persons, Blocked Persons); and (ii) any property or interests in the property of such persons.

Additionally, non-U.S. persons may face some risk of being targeted with so-called “derivative designation” sanctions (which include, among others, blocking sanctions) for materially assisting, sponsoring, or providing “financial, material, or technological support” for, or goods or services to, any SDNs or Blocked Persons targeted under EO 14024 and/or EO 13662. Note that “financial, material, or technological support” is broadly defined under U.S. Russia Sanctions and includes, among other things, “any transmission of value.”

Also on January 10, 2025, OFAC issued several general licenses authorizing otherwise prohibited transactions, subject to certain conditions, for varying periods of time. Among other authorizations, OFAC has licensed the wind down of existing transactions involving certain newly sanctioned persons as of January 10, 2025, until February 27, 2025.

Uncertainty around the Trump administration

The continuing escalation of sanctions detailed above were all implemented during the final days of the outgoing administration and were broadly consistent with the sanctions policy of the Biden administration with respect to Russia since 2022. The Trump administration may pursue a different course. Although, as recently as January 22, 2025, President Trump threatened Russia with additional sanctions, he and various members of the Trump administration have also sounded more conciliatory notes regarding Russia. Most recently, the Trump administration entered into negotiations with Russia over the war in Ukraine, and relaxation of at least some sanctions targeting Russia may be more imminent than appeared even as recently as last week. According to reports released on March 3, 2025, the Trump administration directed the U.S. Department of State and the U.S. Department of the Treasury to draft a list of sanctions that could be eased. These reports state that U.S. officials will discuss this list with Russian representatives during talks, to improve diplomatic and economic relations between the United States and Russia. It is expected that any easing of sanctions might focus on Russian “oligarchs.” It remains to be seen how the U.S. sanctions policy targeting Russia will evolve in the coming months and years. Companies and organizations with potential exposure to Russia and Russian-facing sanctions will need to closely monitor ongoing developments.

EU sanctions: anti-circumvention and claims brought by Russian entities

The EU has continued to be active in expanding its Russia sanctions regime, introducing its 14th, 15th, and 16th sanctions packages in June 2024, December 2024, and February 2025, respectively. A particular focus has been on sanctions circumvention. Protections have also been put in place in response to an increasing wave of legal claims brought by Russian entities against EU corporates. Further, enhancements have also been implemented as regards the due diligence mechanisms. A particularly novel development has been a new “best efforts” requirement on EU entities to ensure that their global subsidiaries do not undermine the EU sanctions regime.

The “best efforts” requirement

Since Russia’s invasion of Ukraine in February 2022, the European Commission has consistently and clearly emphasized, in its Frequently Asked Questions (FAQs), that EU entities and persons are prohibited from using their non-EU subsidiaries to engage in conduct that they themselves would be prohibited from directly undertaking. Such conduct would amount to indirect breaches and/or circumvention of the relevant restrictions. While persuasive, however, the FAQs are not legally binding and do not impose standalone legal obligations. Moreover, the previous measures and this guidance are all based upon the standard paradigm for the imposition of sanctions whereby prohibitions are introduced on dealings with certain persons, sectors, or geographies.

Against this backdrop, and to further tighten the scope of the EU’s restrictions as implemented in practice, the EU’s 14th package introduced a new “best efforts” requirement. This requires EU entities and persons to use their best efforts to ensure that non-EU entities which they “own” or “control” do not participate in activities which undermine the restrictions set forth in Regulation (EU) No. 833/2014 (Regulation 833), the primary piece of EU legislation laying out the EU’s sanctions against Russia. This development is novel in that it imposes a positive legal obligation on EU entities to take steps concerning the activities of their affiliates, which obligation could be breached via a failure or omission to take action (as opposed to the usual situation where sanctions are infringed through engaging in some prohibited act). The requirement is also novel in light of the likely territorial effects of the measure and the conflicts of law issues that it can give rise to.

“Best efforts” are not defined in Regulation 833. The recitals to the 14th package suggest that “best efforts” should be understood as “comprising all actions that are suitable and necessary to achieve the result of preventing the undermining of the restrictive measures in [Regulation 833]”. Examples of such actions are provided, such as the “implementation of appropriate policies, controls, and procedures to mitigate and manage risk effectively, considering factors such as the third country of establishment, the business sector and the type of activity of the legal person, entity or body that is owned or controlled by the [EU] operator.” This understanding is confirmed by the European Commission’s FAQs published in November 2024.

The “best efforts” requirement, introduced in both Regulation 833 and the analogous Regulation (EU) No 765/2006 that sets forth the EU’s sanctions targeting Belarus by the EU’s 14th package, was also extended to Regulation (EU) No. 269/2014 (Regulation 269) in the EU’s 16th package. Regulation 269 sets forth the EU’s asset freeze restrictions targeting a range of Russian entities and persons.

These restrictions will continue to present challenges for many Western companies with a continued presence in Russia. Russia has introduced a broad range of counter-sanctions measures, preventing Russian entities from taking steps to comply with the sanctions regimes of “unfriendly” countries. As a result, many corporate groups likely now face a difficult conundrum whereby EU entities are required to use best endeavors to bring their subsidiaries (including any Russian subsidiaries) into line with EU sanctions, but Russian subsidiaries are prevented by local law from adopting policies in furtherance of EU sanctions. The “best efforts” requirement has forced businesses to look closely at existing corporate structures to decide how far the duty extends, the steps needed to comply, and how to address potential conflicts of law. Notably, the distinction between the approach as (on its face) worded in Regulation 833, and the associated recitals and FAQs would appear to be helpful, suggesting that Member States should take into account the precise circumstances of any particular activity and set of measures adopted. 

Enhanced due diligence measures

The EU has also extended the requirement to include “no-Russia” clauses in contracts with non-EU entities to sales, licenses, and transfers of certain intellectual property rights and trade secrets. Guidance in this regard has been included in the European Commission’s FAQs.

Relatedly, the EU’s 16th sanctions package requires EU operators selling certain “sensitive goods” to third countries to implement due diligence measures to identify, assess, and mitigate the risk of such goods being re-exported to Russia. This may go beyond the “no Russia” clauses required thus far, in that it imposes a positive obligation to conduct due diligence on customers. The European Commission has not, however, published any guidance as to how the substance of any such due diligence measures should look. On its face, though, and in the absence of clarificatory guidance, this new requirement has the potential to become a very onerous obligation on EU operators.

Anti-circumvention measures

There have been several recent changes to the EU’s position on anti-circumvention measures.

For context, in 2011, the Court of Justice of the European Union (CJEU) issued a preliminary ruling on the concept of circumvention under the EU’s sanctions against Iran (Criminal proceedings against Mohsen Afrasiabi and Others [Case C-72/11]). The CJEU held that “circumvention” covered “activities which, under cover of a formal appearance which enables [the operator] to avoid the constituent elements of an infringement of [the relevant prohibition], nonetheless have the object or effect, direct or indirect, of frustrating [that] prohibition.” The CJEU also noted that, for the purpose of the prohibition against circumvention, the terms “knowingly” and “intentionally” imply “cumulative requirements of knowledge and intent” (our emphasis in bold). These requirements could be met where a person is “aware that their participation may have that object or that effect and he accepts that possibility.”

The 14th package formally codified the CJEU’s exposition, expanding upon the prohibition against circumvention in Regulation 833 to specify that circumvention includes “participating in [prohibited] activities without deliberately seeking that object or effect, but being aware that the participation may have that object or effect and accepting that possibility.”

This materially lowers the threshold for triggering this offense. In many instances, decisions as regards sanction-sensitive transactions will inevitably carry a degree of risk. Operators will need to be more mindful than ever as to how they calibrate that risk and ensure that their activities are legally robust.

More broadly, in June 2023, the EU introduced the ability to designate, as EU asset freeze targets, persons or entities that facilitate the circumvention of EU sanctions or that otherwise significantly frustrate the EU’s anti-circumvention prohibitions (see our article here). This authority was exercised in the EU’s 15th package, which included new designations of various Chinese, Indian, Iranian, Serbian, and UAE entities as EU asset-freeze targets. The 16th package expands on this by also including new designations of various entities from Kazakhstan, Singapore, and Turkey. Vessels from third countries which are used to circumvent the G7 oil price cap or otherwise support the Russian energy sector have also increasingly been targeted.

Relatedly, the European Commission has provided additional, more expansive guidance concerning circumvention. Recent FAQs highlight that participation in structures created to avoid the effects of a person’s possible future designation may still constitute circumvention once that person becomes designated. The mere participation in such a structure may suffice to amount to a breach, even if no new assets reach or benefit the designated person.

Knowledge, defense and due diligence

Article 10 of Regulation 833 and article 2 of Regulation 269 provide that actions by EU operators should not give rise to any liability if they did not know, and had no reasonable cause to suspect, that their actions would infringe the EU’s sanctions. The 14th package clarified that this defense cannot be invoked where an EU operator has failed to carry out appropriate due diligence. Such due diligence should take into account publicly or readily available information, be proportionate, and include various controls. At a minimum, EU operators should:

• Screen all parties involved in a transaction. This screening should include both the direct counterparty’s (e.g., customer’s) beneficial owners, as well as those of other parties involved (e.g. upstream suppliers, service providers, banks, etc.).
• Assess the export control-related restrictions that may apply to the goods and services being provided.
• Perform a risk analysis of the transaction. Relevant factors may include the contractual protections included in the transaction documents, the rationale for the transaction, the payment flows involved, the shipment route, the intended end-use of the goods, and any risk that the goods may be diverted.

Protection against claims by Russian companies

Against the backdrop of an increasing number of claims brought by Russian entities against EU operators, recent sanctions packages have introduced several protections for EU operators who dealt with or have or had contractual relationships with Russian entities. Many of these relationships would have existed prior to the invasion of Ukraine and are now being litigated as EU entities have ceased to make payments or deliveries, or provide services, to Russian counterparties, resulting in claims.

First, new measures have been introduced to allow for companies relying on certain provisions in the Russian Arbitration Code to be designated as transaction ban targets (with analogous consequences as the existing transaction ban pursuant to Article 5aa of Regulation 833). The Russian Arbitration Code has sought (as a matter of Russian law) to bring disputes involving a Russian entity targeted by EU sanctions within the exclusive competence of the Russian courts, effectively enabling Russian entities to sidestep EU sanctions by lodging claims against EU operators before the Russian courts. To disincentivize Russian entities from initiating proceedings in Russia, the 14th package permits any entities which rely on these provisions to be designated as transaction ban targets.

Second, the 14th package provided EU operators with an avenue to seek damages from Russian and Russia-connected entities where losses are incurred as a consequence of claims lodged with courts in third countries, in connection with any contract or transaction the performance of which has been affected by EU sanctions. The 16th package even broadened that avenue by clarifying that EU courts should be competent to hear such claims. For this route to be available, the EU operator must not have “effective access to the remedies under the relevant jurisdiction.” Recitals of the 16th package clarify that Union operators can be regarded as being de facto deprived from having effective access to the remedies under those domestic jurisdictions in situations where Russia or another third country takes measures to frustrate compliance with EU sanctions regulations.

Third, the 14th package granted EU operators a right to seek damages from Russian and Russia-connected entities if they benefited from the Russian authorities’ decision to seize Russian assets owned or managed by investors associated with so-called “unfriendly foreign states” (which include the EU Member States). The Russian authorities’ decision must be illegal under international customary law or a bilateral investment treaty entered between an EU Member State and Russia and, as above, the EU operators must also not have “effective access to the remedies under the relevant jurisdiction.”

Fourth, the EU has taken steps under the Energy Charter Treaty (ECT) to deny claims made by Russian and Belarusian investors. The EU and certain Member States have commenced their withdrawals from the ECT, and the EU has also decided that protection under Part III of the ECT will be denied to Russian and Belarusian investors.

Finally, the 15th package prohibits the recognition or enforcement in the EU of rulings issued by Russian courts based on the Russian Arbitration Code. This prohibition was laid down in response to the Russian Supreme Court’s decision in A40-214726/2023 (NS Bank v Lukoil), which ruled that the Russian courts had jurisdiction to hear the claim despite the contract between NS Bank and Lukoil stipulating that disputes would be subject to arbitration by the London Court of International Arbitration.

Other aspects of the EU’s 14th, 15th, and 16th sanctions packages

The EU has imposed a number of additional restrictions in its 14th, 15th, and 16th packages. These include:

• An expansion of the EU’s trade-related restrictions to a wider range of goods.
• A prohibition on EU operators which are owned 25% or more by Russian persons from transporting goods by road within the EU.
• New restrictions targeting Russian-origin LNG. The provision of reloading services for the purpose of transshipment of Russian-origin LNG is now prohibited, as is the sale, supply, transfer, or export of any goods, technology, or services to Russian persons and entities for the completion of LNG projects.
• A restriction on EU entities operating outside Russia from directly connecting to the Central Bank of Russia’s System for Transfer of Financial Messages (SPFS), as well as transaction bans on non-Russian credit or financial institutions that use the SPFS, thereby combating Russia’s attempts to sidestep the G7 SWIFT restrictions by creating a home-grown version of SWIFT.
• A transaction ban on certain credit and financial institutions and crypto-asset providers which are engaged in transactions that facilitate the export (etc.) to Russia of goods targeted by the EU’s trade-related restrictions.
• A prohibition on EU intellectual property offices from accepting certain new applications for trademark and patent registrations that are filed by Russian persons and entities.
• Restrictions on the acquisition of shares by a Russian natural or legal person in certain EU companies (specifically, road transport undertakings) beyond a 25% threshold. This is a notable example of EU restrictions biting below the 50% “ownership” threshold.
• A transaction ban on certain designated ports, locks, and airports in Russia used to transport targeted goods.

We further note that Member States have until May 20, 2025 to transpose EU Directive (EU) 2024/1226, which seeks to harmonize sanctions enforcement across the EU. This Directive seeks to address the disparity in sanctions enforcement between Member States by harmonizing both the type of offense constituted, and the penalties that may potentially be imposed as a result, for sanctions breaches across the EU. Member States, such as Poland, have begun updating their criminal laws as a result, and companies should beware of changing enforcement practice across the EU.

No new EU sanctions were announced on March 10, 2025 when the new EU Commission, headed by President Ursula von der Leyen, summarized its achievements of its first 100 days in office. However, despite suggestions of peace talks, we can expect further sanctions and wider support measures as the EU continues pursuing its efforts to support Ukraine (seen recently by the offer of a Ukraine support package to secure Ukraine’s energy system including its integration into the European energy market, or by proposing an agreement between Ukraine and the Council of Europe for the establishment of a Special Tribunal for the Crime of Aggression against Ukraine).

U.K. sanctions: enforcement and reporting

The U.K. has been less active than the EU in terms of introducing new measures. However, in recent months, it has substantially bolstered its enforcement regime for trade sanctions and placed an increased emphasis on combating sanctions circumvention. The U.K. has also continued to add new designations of entities and individuals under the U.K. sanctions regime.

The launch of the Office of Trade Sanctions Implementation

On October 10, 2024, the Office of Trade Sanctions Implementation (OTSI) was launched. As a sister body to the U.K. HM Treasury’s Office of Financial Sanctions Implementation, OTSI’s focus is on enforcement of the U.K.’s trade sanctions. Its role involves investigating suspected breaches of trade, aircraft, and shipping-related sanctions, monitoring applications for trade licenses, and clamping down on circumvention of the U.K.’s export controls.

In conjunction with OTSI’s launch, the Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 came into effect on October 10, 2024. These regulations supplement existing trade, aircraft, and shipping-related restrictions by introducing new civil enforcement powers, including the ability to impose monetary penalties on a strict liability basis.

Anti-circumvention measures

In alignment with the EU, the U.K. has also sought to clamp down further on sanctions circumvention. A large number of tankers which are part of Russia’s “shadow fleet”, transporting oil and LNG to and from Russia, have now been designated as U.K. asset-freeze targets.

OTSI has published practical guidance to assist businesses with establishing adequate due diligence policies and procedures. This guidance provides an illustrative list of goods that face enhanced export control-related restrictions (e.g., industrial machinery) and sets forth a range of jurisdictions that pose higher risks from a sanctions perspective (e.g., China, India, and Uzbekistan). Businesses are encouraged to carry out enhanced due diligence in relation to transactions with counterparties from these jurisdictions. While this guidance is not legally binding, the approach set forth therein will inform OTSI’s enforcement of the U.K.’s trade sanctions.

“No Russia” clauses

“No Russia” clauses are contractual clauses which prohibit the buyer/importer of goods from re-exporting items, directly or indirectly, to Russia. Such clauses seek to protect sellers from becoming indirectly involved in a breach of sanctions or export controls. In contrast with the EU regime, the U.K.’s Russian sanctions regime does not formally require exporters to include such clauses in their contracts. Recent guidance from OTSI has, however, suggested that such clauses will be regarded as best practice for due diligence. Template wording has also been provided, which may be helpful as a starting point for exporters.

Increasing pace of new designations

On February 24, 2025, the U.K. announced the largest sanctions package against Russia since 2022, with 107 new designations. In summary:

• Targets include producers and suppliers of machine tools, electronics, and dual-use goods for Russia’s military, including microprocessors used in weapons systems. These are based in a range of third countries, including Central Asian states, Turkey, Thailand, India, and China.
• The U.K. Government added 67 new entries to the U.K. sanctions list, including over 30 entities.
• The U.K. has also used for the first time its powers to impose sanctions on persons who provide financial services, or make available funds, economic resources, goods, or technology, to persons involved in obtaining a benefit from or supporting the Russian government. For example, the Kyrgyzstan-based OJSC Keremet Bank has been sanctioned.
• An additional 40 shadow fleet ships have been sanctioned, bringing the total number of oil tankers sanctioned by the U.K. to 133.

Should you have any questions on the matters discussed in this article, please contact any of the contacts listed below or your usual contact at A&O Shearman.

Footnote

1. For these purposes, U.S. persons include U.S. citizens and permanent residents, entities organized under U.S. law (including foreign branches thereof), and persons located in the United States.