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
3/27/2025
/ Compliance ,
Due Diligence ,
Economic Sanctions ,
Enforcement Actions ,
Office of Financial Sanctions Implementation (OFSI) ,
Penalties ,
Regulatory Requirements ,
Reporting Requirements ,
Risk Management ,
Russia ,
UK
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
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
3/17/2025
/ Asset Freeze ,
Economic Sanctions ,
EU ,
Foreign Policy ,
Foreign Relations ,
International Trade ,
National Security ,
NATO ,
Russia ,
UK ,
Ukraine ,
United States
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
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
12/2/2024
/ Cybersecurity ,
Dual Use Goods ,
Due Diligence ,
EU ,
Exporters ,
Exports ,
Misuse of Information ,
Regulatory Agenda ,
Software ,
Surveillance ,
Telecommunications ,
Transparency
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
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
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
7/23/2024
/ Best Practices ,
Buyback Programs ,
Economic Sanctions ,
EU ,
Limited Liability Company (LLC) ,
Majority Shareholders ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Shell Corporations ,
Trusts ,
UK
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
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
12/27/2023
/ Asset Freeze ,
Banking Sector ,
Cryptocurrency ,
Economic Sanctions ,
EU ,
European Economic Area (EEA) ,
Export Controls ,
Fund Transfers ,
G7 ,
Imports ,
Information Sharing ,
Insurance Industry ,
Licensing Rights ,
Metals ,
Oil Prices ,
Pipelines ,
Propane ,
Reporting Requirements ,
Russia ,
SDN List ,
Software ,
Technology Sector ,
Telecommunications ,
Trade Restrictions ,
Transparency ,
UK
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