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OFSI Imposes Monetary Penalty Against Former Moscow Office of International Law Firm for Sanctions Breaches

On March 20, 2025, the U.K.’s Office of Financial Sanctions Implementation (OFSI) announced that, in accordance with section 146 of the Policing and Crime Act 2017 (PACA), a monetary penalty of £465,000 had been imposed...more

The UK Continues to Expand Its Controls on Emerging Technologies

On 11 March 2025, the Department for Business and Trade through the Export Control Joint Unit (ECJU), issued a notice to exporters providing advance notice of updates to the UK Strategic Export Control Lists, which are...more

EU/UK Russia Sanctions: Potential De-escalation of Sanctions and Divergence from U.S. Regime

Background - The war in Ukraine has taken a new diplomatic turn in recent weeks. Having historically aligned with the European Union (EU) and United Kingdom (UK) on its condemnation of Russia’s war in Ukraine, and the need...more

Challenging Final Orders Under the NSIA – Merely Difficult, or Impossible?

Scottish chip firm loses temporary injunction application for relief while divestment decision is challenged by judicial review, following the UK issuing its third Annual Report on the NSIA. The UK High Court of Justice has...more

Guidelines on the Export of Cyber-surveillance Items Under Article 5 of Regulation 2021-821

In 2021, the European Union (EU) updated the EU Dual-Use Regulation, setting unified standards for EU member states to control exports of dual-use items. A key addition in Regulation (EU) 2021/821 is Article 5’s “catch-all...more

Extraterritorial Application of EU Sanctions Targeting Russia?

On 22 November 2024, the European Commission (the “Commission”) issued new frequently asked questions (FAQs) regarding the interpretation of the “Best Efforts” obligation in Article 8a of Council Regulation (EU) No. 833/2014...more

UK Government Announces New Civil Enforcement Powers on Trade Sanctions and Launch of Office of Trade Sanctions Implementation

Key Takeaways - On 12 September 2024, the UK government published the Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 (the “Regulations”), which will come into force on 10 October 2024. The...more

EU Publishes New Best Practices Guidance, including Updated Ownership Test and Additional Control Guidance

Key Takeaways - On 3 July 2024, the Council of the European Union (the “EU Council”) published its revised Update of the EU Best Practices for the effective implementation of restrictive measures (“Best Practices”).This...more

International Unilateral Export Controls—An Increased Focus on Advanced Technologies

On 11 March 2024, the UK expanded its export control regime to include new controls on specific emerging technologies, such as quantum computing, semiconductor technologies and additive manufacturing, under The Export Control...more

New EU & UK Sanctions

EU’s 12th Sanctions Package - On 19 December 2023, the Council of the European Union (EU) together with the Commission published its 12th round of sanctions....more

Bank Otkritie v Mints Case and Ownership and Control

Key Takeaways - On 17 November 2023, the Foreign, Commonwealth & Development Office (FCDO) and Office of Financial Sanctions Implementation (OFSI) published new guidance on Ownership and Control: Public Officials and...more

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