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EU and UK Sanctions Briefing: The Luxury Goods Sector

The Impact of the EU and UK Russian Sanctions Regime on the Luxury Goods Sector - As the EU and UK Russian sanctions regimes continue to evolve, export controls are now affecting industries previously not often subject to...more

European Union Adopts New Sanctions Against Russia and Belarus

The European Union has again amended its sanctions against Russia and Belarus by adopting further legal acts, which put additional compliance obligations on EU companies. In particular, businesses will now have to undertake...more

How the Serious Fraud Office's Ambitious Five-Year Strategy Will Impact Businesses

The Serious Fraud Office (SFO) recently published its new five-year strategy for 2024-2029 (the Strategy), setting out its ambitious aspirations to become a “pre-eminent specialist, innovative and collaborative agency which...more

The Year Ahead: The Financial Conduct Authority's Ambitious Enforcement Plans for 2024/2025

In 2022, for the first time, the Financial Conduct Authority (FCA) published a three-year strategy setting out three key themes for promoting positive change, namely: (1) reducing and preventing serious financial harm and...more

UK and EU Sanctions Update–April 2024

The following alert provides an update on recent sanctions developments, including: The publication of the UK government’s first sanctions strategy. The announcement of over 50 new sanctions. Measures to strengthen the Oil...more

New Government Guidance and UK High Court Seeks to Settle Disarray in UK Sanctions Law

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

Why Corporates Are Now More Likely to Face Criminal Prosecution for the Actions of Their Employees

Significant Expansion to Corporate Criminal Liability Becomes Law in the United Kingdom - On 26 October 2023, the Economic Crime and Corporate Transparency Act (the Act) became law. Under the Act, corporations will become...more

UK Sanctions Law in Disarray? What You Need to Know

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

FCA Publishes Outcome of its Review of Firms' Compliance with Sanction Controls

Introduction - Since the Russian invasion of Ukraine in February 2022 the UK has introduced an unprecedented number and variety of sanctions. The FCA has recently assessed the sanctions controls of over 90 financial service...more

UK Real Estate Ownership and the Implications of the Economic Crime (Transparency and Enforcement) Act

On 2 August 2023, the Register of Overseas Entities (ROE) update process went live. UK Companies House issued guidance on the requirements overseas entities will have to adhere to in their annual update of the ROE. Our...more

Corporate Criminal Liability – What is Next for the United Kingdom?

It is no great secret that criminal enforcement in the United Kingdom against corporations has lagged behind our counterparts in the United States and other jurisdictions. In recent years the UK government has introduced a...more

UK Sanctions Update – July 2023

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

UK Sanctions Update – June 2023

The United Kingdom export control authorities continue escalating sanctions and export controls in relation to Russia and Belarus. We have summarised below the key points from some of the most recent developments and provided...more

PRA Enforcement Changes - The Good, the Bad, and the Ugly

On 4 May 2023, the Bank of England (BOE) and the Prudential Regulation Authority (PRA) published a consultation paper on the proposed changes to their enforcement procedures and policies. The consultation is due to close on 4...more

Russia-Related Export Controls Continue to Escalate

In a set of actions in coordination with G7 allies, US and UK export control authorities recently announced significant escalations of sanctions and export controls against Russia and Belarus. These actions indicate continued...more

Cryptoasset Regulatory Update: HM Treasury Publishes Consultation Paper on the Future of the Financial Services Regulatory Regime...

Introduction - On Wednesday, 1 February 2023, HM Treasury announced its intention to regulate a variety of crypto-asset activities under the UK financial services regulatory regime. The announcement arrived in the form of a...more

PSJC v Mint – A Road Map for Litigation Involving Sanctioned Individuals or Entities?

A recent judgment by London’s Commercial Court has shed light on the effect of Russian sanctions on ongoing litigation in the United Kingdom (UK). The Sanctions and Anti-Money Laundering Act 2018 (SAMLA) provides the main...more

Sanctions Update—January 2023

The following alert provides an update on recent sanctions developments including: 1. A £30,000 fine imposed for breaches of UK sanctions; 2. The expansion of the prohibition on providing professional services to persons...more

OFSI Annual Review: April 2021 to August 2022

On Thursday 10 November 2022, the UK Office of Financial Sanctions Implementation (OFSI), published its 2021-2022 annual review, highlighting its shift towards a more proactive rather than reactive compliance and enforcement...more

Where the United States Goes, the FCA Will Inevitably Follow: Regulatory Action Against the Use of Personal Mobile Devices

The ability to maintain effective and accurate recordkeeping, a key method of ensuring market integrity, has been tested in recent years. The widespread use of personal mobile devices, instant messaging services, and general...more

Challenges for Challengers – the FCA Shares Its Expectations for Financial Crime Controls at Disruptor Banks and Provides Lessons...

The Financial Conduct Authority’s (FCA) expectations for challenger banks provide lessons for all in the financial service industry. Challenger banks, offering updated consumer experiences and disrupting standard practice...more

Lessons to be Learned – FCA Fines JLT Specialty Limited £7.8 Million for Financial Crime Control Failings

In June of this year, the Financial Conduct Authority (FCA) took enforcement action against JLT Specialty Limited (JLT) for the second time in the space of a decade. The fine of approximately £7.8 million is in response to...more

FCA Calls for Sanctions Evasion Reporting

On 17 May 2022 the UK Financial Conduct Authority (FCA) made an appeal for people to report to it regarding firms on the Financial Services Register or other FCA registers, or companies with UK listed securities that have...more

UK Sanctions Update - Ban on Services and Prevention of Disinformation

On Wednesday 4 May, Foreign Secretary Liz Truss announced a ban on the export of services by UK persons or entities to businesses in Russia. Prohibited services include accountancy, management consultancy, and public...more

Timber Briefing: U.S. Lumber Prices Could Be Affected By Sanctions on Russia

The U.S. lumber market has seen unprecedented price rises in recent years. Prices could climb even higher as the world responds to the conflict between Russia and Ukraine. Russia is a major exporter of wood in the global...more

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