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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

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