In its first-ever threat assessment of the UK legal sector, the UK’s Office of Financial Sanctions Implementation (OFSI) has raised red flags with regards to suspected sanctions breaches involving UK legal services providers...more
The United Kingdom’s Financial Conduct Authority (FCA) has announced significant changes to its regulatory approach, including dropping the obligation to “name and shame” firms under investigation, dropping the proposed...more
On 13 February 2025, the Office of Financial Sanctions Implementation (OFSI) published its assessment of suspected sanctions breaches involving financial services firms since February 2022 (the Assessment). The Assessment...more
In November 2024, the UK FCA released a Consultation which seeks to clarify its proposed approach to publicising ongoing enforcement action—dubbed the “name and shame” plan—and to assure the wider market of the plan’s...more
On 27 February 2024, the Financial Conduct Authority (FCA) published its Consultation Paper CP24/2, which revealed the FCA’s new intended approach to publicised enforcement action. This was quickly dubbed the “name and shame”...more
The Financial Conduct Authority (FCA) recently levied a jaw-dropping £29 million fine against Starling Bank (Starling). The fine follows an investigation by the regulator, which exposed the bank's "shockingly lax" sanctions...more
On 24 September 2024, the G7 released updated guidance on the prevention of evasion of export controls and sanctions imposed on Russia. The aim of the guidance is to “assist industry in identifying Russian evasion practices...more
On 12 September 2024, the UK government released the new Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 (the Regulations), which will come into force on 10 October 2024. The Regulations grant the...more
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
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
4/12/2024
/ Asset Freeze ,
Economic Sanctions ,
EU ,
Export Controls ,
Exports ,
Imports ,
New Regulations ,
Oil & Gas ,
Regulatory Oversight ,
Russia ,
Sanctions and Anti-Money Laundering Act 2018 (SAMLA) ,
Trade Relations ,
UK
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
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
11/21/2023
/ Bribery ,
Compliance ,
Corporate Liability ,
Corporate Transparency Act ,
Criminal Liability ,
Criminal Prosecution ,
Due Diligence ,
Fraud ,
Money Laundering ,
Risk Assessment ,
Senior Managers ,
UK ,
White Collar Crimes
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
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
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
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
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
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
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
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
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
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
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
Russia’s invasion of Ukraine and subsequent revelations of alleged atrocities in territories previously controlled by Russia have had a global impact. Dozens of foreign countries (States) have imposed a wide variety of...more
4/20/2022
/ Blocking Sanctions ,
Economic Sanctions ,
EU ,
Financial Transactions ,
Foreign Investment ,
Foreign Policy ,
Popular ,
Russia ,
SDN List ,
Trade Restrictions ,
UK ,
Ukraine
What is it? On 15 March 2022 the Economic Crime (Transparency and Enforcement) Act 2022 (the Act) received royal assent, having been expedited through parliament as part of the United Kingdom’s response to Russia’s invasion...more