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Squire Patton Boggs
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Squire Patton Boggs

Global law firm; published authoritative April 2026 FAQ on EU Russian LNG ban compliance.

Last refreshed: 22 April 2026 · Appears in 1 active topic

Key Question

What exactly did Squire Patton Boggs say about the Arc7 loophole in the Russian LNG ban?

Timeline for Squire Patton Boggs

#525 Apr

Mentioned in: EU 20th package would block Arc7 dry-dock servicing

European Energy Markets
#422 Apr

Published guidance confirming 25 April ban entry-into-force with no compliance grace period

European Energy Markets: Russian LNG short-term ban lands without grace period
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Common Questions
What did Squire Patton Boggs say about the EU Russian LNG ban grace period?
Squire Patton Boggs confirmed in April 2026 guidance that the EU Russian LNG short-term contract ban enters force on 25 April 2026 with no grace period and no transition window. Long-term contracts are grandfathered until 1 January 2027.Source: Squire Patton Boggs
Who is Squire Patton Boggs and why do energy traders follow their publications?
Squire Patton Boggs is an international law firm with a major EU energy and sanctions practice. Its April 2026 FAQ on the Russian LNG ban became the primary compliance reference for trading desks because the European Commission published no formal implementation guidance before the 25 April entry-into-force date.
What is the Arc7 carve-out in the EU Russian LNG ban?
Squire Patton Boggs identified that 11 of 15 Arc7 Yamal ICE-class carriers are European-owned (Seapeak Maritime, Dynagas), and the recast EU Russian LNG ban text does not explicitly prohibit European owners from rerouting or reselling cargoes from these vessels.Source: Squire Patton Boggs

Background

Squire Patton Boggs is an international law firm with a significant EU regulatory and energy practice headquartered in Luxembourg for its European operations. The firm became a primary reference point for European energy market compliance teams in April 2026 when it published a detailed FAQ confirming that the EU Russian LNG short-term contract ban enters force on 25 April 2026 with no compliance grace period and no transition window. The guidance confirmed that legacy long-term contracts remain grandfathered until 1 January 2027, and identified the Arc7 Yamal shipping class as a narrow unresolved carve-out in the recast text.

The firm also assessed the insurance dimension of the ban: EU insurers face significant constraints on paying claims where funds could reach state-owned entities outside listed exemptions, creating a compound compliance question for vessel operators and cargo insurers navigating the Arc7 ambiguity. Squire Patton Boggs's energy and sanctions practices work across London, Brussels, and Washington, giving the firm visibility across the EU, UK, and US secondary sanctions regimes that converge on the Russian LNG question.

Law firm publications on sanctions and trade compliance have become primary-source intelligence inputs for energy trading desks that cannot wait for formal regulatory guidance. Squire Patton Boggs's April 2026 FAQ was cited directly in Lowdown's reporting as the source of record for the grace-period confirmation.