On October 22, 2025, the U.S. government imposed property-blocking sanctions on Russia’s two largest oil companies, Open Joint Stock Company Rosneft Oil Company (“Rosneft”) and Lukoil OAO (“Lukoil”), by designating these entities, as well as 34 Russia-based Rosneft and Lukoil subsidiaries, to the List of Specially Designated Nationals and Blocked
Continue Reading U.S. and UK Sanctions Target Russia’s Two Largest Oil Companies; EU Issues Significant New Russia and Belarus Sanctions Package
Eric Carlson
Eric Carlson has nearly two decades of experience advising clients operating in China and other jurisdictions in Asia on compliance and investigations matters, particularly in the areas of export controls/sanctions and fraud/corruption/FCPA.
Having lived in China for more than a decade, Eric has deep experience leading highly sensitive investigations in China and other jurisdictions in Asia, including investigations presenting complex legal, political, and reputational risks in the areas of export controls/sanctions, anti-corruption/FCPA, fraud, and accounting irregularities. He has assisted numerous clients in responding to subpoenas and inquiries from government agencies in the United States, China, and other jurisdictions, and navigating cross-border data transfer restrictions during internal and government investigations. Eric speaks Mandarin and Cantonese and has led more than four hundred witness interviews in Chinese in 24 provinces in China, and conducted dozens of trainings in Chinese. He is a Certified Fraud Examiner.
Eric also counsels clients on the compliance risks of proposed transactions, conducts compliance due diligence as part of mergers, acquisitions, and joint ventures, assists companies in updating and strengthening their internal compliance programs and tailoring them to the unique features of Asian markets, and developing and presenting tailored compliance training in Chinese and English. Eric has advised scores of companies and organizations representing nearly every major industry.
Eric is a regular speaker and author on China-related export controls/sanctions and anti-corruption/fraud issues. He has been quoted in publications such as
The Wall Street Journal
,
The Economist, The Financial Times, Global Investigations Review, Compliance Week, FCPA Report, The Corporate Treasurer, Commercial Dispute Resolution, China Business Law Journal,
and
Economy and Nation Weekly
and
was a contributing editor to the
FCPA Blog.
Chambers notes that Eric has “much more than just a conversational grasp of the language, but the ability to conduct interviews on specific subject matter details and get to the root of the issues." Chambers further notes that "his language skills are very impressive" and that he provides "great advice that is grounded in reality," adding: "They know the industry and their advice is very risk-based and balanced." One client noted to Chambers: "They have strong regional coverage both in terms of footprint as well as language skills. If I have a compliance investigation in region with a tight timeframe, I know they can get it done. They take a more realistic approach to scoping investigations." Other clients noted to Chambers that Eric is "really brilliant" and "an expert in this field." According to one client surveyed by Chambers, "he is particularly adept at 'right sizing' the scope of an investigation to get at the key issues without incurring unnecessary operational or financial burden. He is also incredibly responsive to client communications."
U.S. Department of Commerce Expands End-User Controls to Cover Affiliates of Certain Listed Entities
On September 29, 2025, the U.S. Commerce Department, Bureau of Industry and Security (“BIS”) issued an interim final rule titled Expansion of End-User Controls to Cover Affiliates of Certain Listed Entities (the “Affiliates Rule”).
Click here to read the full alert on cov.com
Continue Reading U.S. Department of Commerce Expands End-User Controls to Cover Affiliates of Certain Listed EntitiesReimposition of UN-Mandated Sanctions Against Iran and Additional EU and UK Sanctions
On 29 September 2025, United Nations (“UN”) nuclear-related sanctions against Iran, which were suspended in 2015, were reimposed following action at the UN Security Council by France, Germany, and the United Kingdom. In parallel, the European Union (“EU”) and United Kingdom (“UK”) also reintroduced autonomous sanctions measures against Iran that…
Continue Reading Reimposition of UN-Mandated Sanctions Against Iran and Additional EU and UK SanctionsU.S. Commerce Department Eases Export Control Restrictions for Syria
On September 2, 2025, the U.S. Commerce Department, Bureau of Industry and Security (“BIS”) published in the Federal Register a final rule titled Relaxing Export Controls for Syria (the “Syria Export Controls Rule”). The rule eases certain export controls applicable to Syria under the Export Administration Regulations (“EAR”) by adding…
Continue Reading U.S. Commerce Department Eases Export Control Restrictions for SyriaDOJ White Collar Enforcement Six Months into the Trump Administration
Now that the Trump Administration has cleared the six-month mark, its approach to white collar enforcement is starting to come into focus through multiple policy announcements and an emerging track record. After a flurry of policy announcements from Attorney General Pam Bondi in the early weeks of the new administration…
Continue Reading DOJ White Collar Enforcement Six Months into the Trump AdministrationNew U.S. and UK Sanctions, Including Related to Russia’s Energy Sector
On January 10, 2025, the U.S. Department of the Treasury and U.S. Department of State intensified sanctions against Russia with new measures targeting Russia’s energy sector. According to the Treasury Department’s press release, these measures are intended “to fulfill the G7 commitment to reduce Russian revenues from energy” and “substantially increase the sanctions risks associated with the Russian oil trade.”
The new U.S. sanctions include a determination by the U.S. Department of the Treasury authorizing the imposition of property-blocking sanctions against any person who is determined by the Treasury Secretary or Secretary of State (in consultation with one another) to operate or have operated in the Russian energy sector, and a determination issued by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) prohibiting—effective February 27, 2025—the provision of “petroleum services” from the United States or by a U.S. person to any person located in Russia. In addition, OFAC and the U.S. Department of State collectively designated for property-blocking sanctions more than 400 individuals, entities, and vessels from various countries involved in Russia’s energy sector, including two of Russia’s most significant oil producers and exporters—Public Joint Stock Company Gazprom Neft (“Gazprom Neft”) and Surgutneftegas, along with more than two dozen of their subsidiaries. The designations included more than 180 vessels, many of which are part of Russia’s “shadow fleet” of vessels involved in the trade of Russian oil, as well as several Russian energy executives, oil traders, oilfield service providers, and financial and insurance entities associated with Russia’s energy sector. The designations also covered two active Russian liquefied natural gas (“LNG”) projects and a Russian oil project.
On January 15, 2025, the U.S. Department of the Treasury and U.S. Department of State designated or re-designated under additional sanctions authority nearly 250 individuals and entities for property-blocking sanctions, including actors based in China.
OFAC also issued multiple general licenses related to the above designations, including a general license authorizing until February 27, 2025, transactions ordinarily incident and necessary to the wind down of transactions involving Gazprom Neft and Surgutneftegas, their designated subsidiaries, and entities that they own 50 percent or more, directly or indirectly, individually or in the aggregate, subject to certain conditions. In addition, OFAC revoked a general license that had authorized transactions with certain vessels subject to U.S. property-blocking sanctions due to their ownership, and amended two existing general licenses. One of these amended general licenses, General License 8L (which supersedes General License 8K), significantly narrows the scope of permissible energy transactions involving certain blocked financial institutions to include only wind-down transactions until March 12, 2025.Continue Reading New U.S. and UK Sanctions, Including Related to Russia’s Energy Sector
China Enacts Broad Counter-Terrorism Law
On December 27, 2015, the Standing Committee of the National People’s Congress (NPC), China’s top legislative body, enacted a Counter-Terrorism Law (see the Chinese version here), which took effect on January 1, 2016. The adoption of this law, a year after the first draft was released for public comment, followed…
Continue Reading China Enacts Broad Counter-Terrorism Law