The simultaneity paradox under REMIT II refers to a conflict in implementing rules that would have required energy companies to report the same transaction to two EU authorities simultaneously under different timelines. Baker McKenzie's April 2026 guidance identified a transition period that eases this dual-reporting burden.Source: Baker McKenzie REMIT II guide, April 2026

What does Baker McKenzie advise on European energy market compliance?

Baker McKenzie's energy practice advises on REMIT II reporting obligations, EU sanctions compliance, and trade in energy commodities. In April 2026 it published a REMIT II implementation guide timed to the Madrid Gas Regulatory Forum.Source: event

What is Baker McKenzie known for in energy law?

Baker McKenzie's Energy, Mining and Infrastructure practice advises on EU and UK energy regulation, including REMIT II compliance, trade sanctions, and cross-border transaction structuring. Its European offices are particularly active in energy regulatory advisory work.Source: Baker McKenzie entity background

Background

Baker McKenzie is one of the world's largest international law firms by headcount, headquartered in Chicago with major offices across Europe, Asia, and the Middle East. Its Energy, Mining and Infrastructure practice and its trade and sanctions team are prominent in European energy regulation advisory work.

In April 2026 Baker McKenzie published a REMIT II compliance guide flagging the transition period that softens the so-called simultaneity paradox: a quirk in the EU Regulation on Wholesale Energy Market Integrity and Transparency's implementing rules that would have required energy companies to report the same transaction to two different authorities simultaneously under different timelines. The guide was timed to the 40th Madrid Gas Regulatory Forum on 29-30 April 2026, where REMIT 2.0 compliance was a key agenda item.

Baker McKenzie's trade and sanctions practice is also active in advising European energy market participants on OFAC General Licences governing Russian crude. The firm provided analysis on GL 134C and GL 131F during the May-June 2026 ISAB Priolo Gargallo refinery sale process, clarifying the scope of the in-transit waiver and the Cuba carve-out for European buyers and refiners navigating the sanctions perimeter around Russian-origin cargoes. Its REMIT and sanctions guidance sits alongside that of regulatory technology firm KOR Financial in the reference corpus cited by European energy market participants.

More questions

What is the simultaneity paradox in REMIT II?

The simultaneity paradox arises from the REMIT II implementing regulations requiring energy companies to report the same transaction to two different authorities simultaneously under different timelines. Baker McKenzie's April 2026 compliance guide explained that a transition period softens this obligation.Source: European Energy Markets topic

Where is Baker McKenzie headquartered?

Baker McKenzie is headquartered in Chicago, USA, with major offices across Europe, Asia and the Middle East. Its European offices handle EU energy and trade regulation advisory work.Source: Baker McKenzie entity background

How many lawyers does Baker McKenzie have?

Baker McKenzie is one of the world's largest law firms by headcount, with over 13,000 staff across more than 70 countries.Source: Baker McKenzie public record

What is the REMIT II simultaneity paradox that Baker McKenzie flagged?

The simultaneity paradox is a quirk in REMIT II implementing rules that would require energy companies to report the same transaction to two different authorities under different timelines simultaneously. Baker McKenzie's April 2026 guide identified a transition period that softens this dual-reporting burden during the initial implementation phase.Source: European Energy Markets briefing

What does General Licence 134C allow for European oil buyers?

GL 134C is an OFAC licence authorising certain services for Russian crude loaded by 17 April 2026, providing a wind-down period for in-transit cargoes. It excludes Cuba outright; any cargo with Cuban involvement loses GL 134C cover entirely. It was set to expire on 17 June 2026 with no successor GL 134D announced.Source: European Oil Markets briefing

What is Baker McKenzie known for in European energy law?

Baker McKenzie's Energy, Mining and Infrastructure practice and trade and sanctions team advise European energy companies on EU market regulation (REMIT II), OFAC sanctions compliance for Russian-origin crude, and energy transition policy. Its analysis is widely cited by trading houses, utilities, and refiners.Source: European Energy Markets briefing

How the World Sees Them

United States

Baker McKenzie's Chicago HQ is outside EU jurisdiction; its European offices publish the compliance analysis relevant to EU energy market participants.

United Kingdom

Post-Brexit UK energy firms operating in EU markets still face REMIT II obligations for EU-side transactions; Baker McKenzie's London office covers the cross-border dimension.

European Union (ACER)

ACER monitors compliance guidance from major law firms to understand how industry is interpreting REMIT II transition-period provisions.

European energy companies

Baker McKenzie's REMIT II and OFAC GL analysis is a primary reference for compliance officers at trading houses navigating dual reporting and sanctions constraints.