On 1 March 2022, the UK Government introduced into Parliament the Economic Crime (Transparency and Enforcement) Bill (the "Bill"). The draft legislation contains a number of measures designed to increase transparency and give...more
On 26 April 2021, the UK government brought into force a new sanctions regime, designed to target individuals involved in serious corruption and prevent them from entering the UK or using the UK financial system. To date, 22...more
In January 2018, UK law enforcement agencies were granted new powers to pursue the forfeiture of assets. Unexplained wealth orders ("UWOs") initially grabbed the media's attention, but the relative ease with which UK law...more
On March 25, 2021, the United States imposed sanctions on Myanma Economic Holdings Public Company Limited ("MEHL") and Myanmar Economic Corporation Limited ("MEC"), Burma's two largest military conglomerates. On the same day,...more
Much has been made of the Supreme Court's decision earlier this month in KBR, Inc. v Director of the Serious Fraud Office, in which it confirmed the limits on UK authorities' reach overseas in anti-corruption investigations....more
2/24/2021
/ Criminal Investigations ,
Criminal Justice Act ,
Extraterritoriality Rules ,
Financial Crimes ,
Foreign Corporations ,
Foreign Jurisdictions ,
KBR (formerly Kellogg Brown & Root) ,
Multinationals ,
Serious Fraud Office (SFO) ,
UK ,
UK Supreme Court
On 6 July 2020, the UK adopted its first autonomous sanctions regime, imposing asset freezes and travel bans on 47 individuals and two entities across the world accused of serious human rights violations. The new regime marks...more
The UK sanctions authority, the Office of Financial Sanctions Implementation (OFSI), has announced its first multi million pound fine since its establishment in 2016. The fine confirms OFSI’s increasing enforcement activity...more
On May 8, 2019, following Iran's announcement that it intends to suspend certain nuclear proliferation-related commitments under the Joint Comprehensive Plan of Action (JCPOA), the United States issued a new Executive order...more
5/14/2019
/ Blocking Sanctions ,
Blocking Statutes ,
CAPTA List ,
China ,
Economic Sanctions ,
EU ,
Executive Orders ,
Foreign Financial Institutions (FFI) ,
France ,
Germany ,
IFCA ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Metals ,
Nuclear Power ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Prohibited Transactions ,
SDN List ,
Steel Industry ,
Suspensions ,
Trump Administration ,
UK ,
Waivers
Following mounting calls for reform of the UK's corporate criminal liability regime, the Government is expected to consult later this year on potential reforms, which are likely to include a new corporate offence of failing...more
3/14/2019
/ Compliance ,
Corporate Crimes ,
Corporate Liability ,
Corporate Misconduct ,
Criminal Liability ,
Failure to Prevent ,
Financial Crimes ,
Money Laundering ,
Proposed Amendments ,
Proposed Rules ,
Serious Fraud Office (SFO) ,
UK Bribery Act ,
UK Criminal Finances Act 2017
With Brexit looming, the UK's autonomous sanctions policy is slowly taking shape. This month saw the publication of regulations setting out the post-Brexit UK sanctions regimes for Iran, Burma and Venezuela, which will come...more
3/4/2019
/ Asset Freeze ,
Blocking Statutes ,
Burma ,
Economic Sanctions ,
EU ,
General Licenses ,
Information Sharing ,
Iran ,
Joint Comprehensive Plan of Action (JCPOA) ,
No-Deal Brexit ,
Office of Financial Sanctions Implementation (OFSI) ,
Ownership Rules ,
Reporting Requirements ,
Right to Control ,
Sanctions and Anti-Money Laundering Act 2018 (SAMLA) ,
UK ,
UK Brexit ,
Venezuela
On 31 January 2019, France, Germany and the United Kingdom (the "E3") announced the registration in France of INSTEX SAS ("Instrument for Supporting Trade Exchanges"), which is a special purpose vehicle aimed at facilitating...more
2/14/2019
/ AML/CFT ,
Blocking Statutes ,
EU ,
FATF ,
France ,
Germany ,
INSTEX ,
International Atomic Energy Agency ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Special Purpose Vehicles ,
UK ,
United Nations
On 21 January 2019, the EU adopted the first sanctions measures under its new sanctions framework targeting parties involved in the use and proliferation of chemical weapons introduced in October 2018...more