US SANCTIONS - US Department of the Treasury Takes Further Action against Russia’s International Supply Chains: On August 23, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the US...more
The UK’s National Crime Agency (NCA) recently secured its first forfeiture of sanctioned funds. This was a landmark achievement for the NCA’s Combatting Kleptocracy Cell, which has only existed since 2022 and aims to...more
The UK’s latest sanctions affect multiple areas and actors, including Turkish, Chinese, and Dubai-based entities alleged to support Russian military activities. This Client Alert is published in the context of ongoing...more
2023 was another significant year for UK sanctions. The UK government has continued to implement new sanctions against Russia in response to its illegal war in Ukraine, including through new designations, broadened financial...more
1. Russia Sanctions - UK Government increases the deadline for providing certain information in relation to the Maritime Services Ban and Oil Price Cap Exception: On March 8, 2024, the UK Government increased the deadline...more
On 22 February 2024, shortly before the second anniversary of Russia’s invasion of Ukraine, the UK government published its first sanctions strategy (the Strategy). The Strategy explains the UK’s use and implementation of...more
Almost six years have passed since the introduction of the UK Sanctions and Money Laundering Act, and two years since Russia's invasion of Ukraine, which was a watershed moment for the UK sanctions regime. Against the...more
2023 was another record year for U.S. sanctions and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). Most prominently, OFAC continued to impose significant additional sanctions on Russia in...more
I. US SANCTIONS - US Department of the Treasury Sanctions Almost 300 Individuals and Entities: On February 23, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned almost 300 individuals...more
In this weekly update, we summarise the most notable updates in the UK sanctions world. ...more
In this weekly update, we summarise the most notable updates in the UK sanctions world. If you have any questions in respect of any of the developments set out below, please do not hesitate to contact a member of our London...more
For over eighteen years the “who’s who” in the global sanctions’ community has attended 18th Annual Flagship Conference on Economic Sanctions Enforcement and Compliance– which is widely regarded as the premier conference for...more
Immerse yourself in the only comprehensive economic sanctions event of its kind in Canada, spanning two days of invaluable insights and practical knowledge. Designed to cover U.S., EU, and major global sanctions, this...more
The UK Office of Financial Sanctions Implementation (OFSI) and the Foreign, Commonwealth and Development Office (FCDO) recently published important guidance on the meaning of ‘ownership and control’ in the context of UK...more
On 6 October 2023, the Court of Appeal handed down judgment in the case of Mints & ors v PJSC National Bank Trust & anor [2023] EWCA 1332. The judgment confirmed that the UK’s sanctions do not preclude the English courts...more
In October, the Court of Appeal suggested all companies operating in Russia could be considered to be sanctioned under UK law because they are potentially controlled by President Putin. This caused understandable alarm to...more
A non-binding passage in a recent Court of Appeal judgment has suggested that any company based in or incorporated in Russia could be subject to the same UK sanctions as Vladimir Putin. The UK Foreign, Commonwealth and...more
Back by popular demand, ACI’s acclaimed 13th Annual New York Forum on Economic Sanctions returns to NYC this December. Regarded as the must attend conference for legal and compliance professionals working for financial...more
Enforcement and legal risks relating to sanctions compliance remain high and all firms should continue to exercise care in meeting regulatory expectations. The promulgation of new sanctions relating to Russia has slowed but...more
Background - In response to Russia’s invasion of Ukraine in February 2022 the UK, in parallel with the U.S. and the EU, significantly expanded its sanctions against Russia by imposing wide restrictions on trade, aircraft,...more
The UK Financial Conduct Authority (FCA) has assessed the systems and controls relating to sanctions compliance for over 90 firms across a range of sectors and summarised its findings of good and poor practice. Acknowledging...more
On 14 April 2023, the Governor of the Cayman Islands issued a general licence (GL/2023/0002) for the payment of legal fees (the “Cayman General Licence”). This means that, under specified circumstances, Designated Persons...more
July was another busy month for sanctions in the United Kingdom. We have prepared a briefing on the key recent developments and suggested practical steps for companies and legal professionals to assist in understanding the...more