Looking The Other Way: Recent Cases Of AML And Sanctions Failings In Scandinavia
The UK’s National Crime Agency (NCA) recently secured its first forfeiture of sanctioned funds. This was a landmark achievement for the NCA’s Combatting Kleptocracy Cell, which has only existed since 2022 and aims 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
Transparency or privacy – which of these priorities prevails? A ruling on 22 November 2022 by the Court of Justice of the European Union (CJEU) might mean privacy prevails when it comes to the question of whether or not a...more
Charles Goldblatt, litigation associate at Conyers in the British Virgin Islands, takes a close look at how local judges are addressing sanctions against Russian entities. Since Russia's military incursion in Ukraine...more
Since Russia’s military incursion in Ukraine began on 24 February 2022, the UK has introduced an extensive package of economic sanctions against Russia. By the end of August 2022, over 1,270 persons had been designated and by...more
Elizabeth Holmes Sentenced to 11 Years in Prison - On November 18, 2022, former Theranos CEO, Elizabeth Holmes, was sentenced to 11 years and three months in prison for defrauding investors regarding Theranos’ blood...more
On 2 September 2022, HM Government – through the Treasury – exercised its power to request information by issuing a financial sanctions notice requesting that all persons that hold or control funds or economic resources...more
The UK has long implemented sanctions imposed by the United Nations and, before Brexit, the European Union (EU). Since the UK’s departure from the EU, the UK government has sought to both preserve the policy objectives of...more
Ensuring compliance is key for an organization’s success. The ongoing conflict in Ukraine is a salient reminder that the world shifts on its axis from time to time, and many of our working assumptions have to go by the...more
The U.K. Office of Financial Sanctions Implementation has published a revised General License under the Russia (Sanctions) (EU Exit) Regulations 2019. The License was first published on February 25, 2022, and allows...more
As a further response to Russia’s invasion of Ukraine, the Economic Crime (Transparency and Enforcement) Act (the “Act”) has been fast-tracked into law and received royal assent in the early hours of 15 March 2022. The Act,...more
Key Points - The proposed power would allow the UK Government to block initial equity listings and admissions on UK public markets on the grounds of national security. The listing of debt securities (other than...more
On 26 April 2021, the UK Government announced a new sanctions regime specifically targeting corruption. Following the introduction of the Global Anti-Corruption Sanctions Regulations 2021 (the Regulations), the UK Government...more
The regulations will enable the UK government to impose sanctions in response to serious corruption around the world. On 26 April 2021, the United Kingdom implemented the Global Anti-Corruption Sanctions Regulations 2021 (the...more
On April 26, 2021, the UK announced a new global anti-corruption sanctions regime and has imposed sanctions on 22 people whom the UK Government has reasonable grounds to suspect have been involved in serious corruption. Under...more
Following the UK’s withdrawal from the EU, effective 11 pm UK time on 31 December 2020, the UK (with the exception of Northern Ireland in some cases) no longer automatically implements EU laws. This has brought about...more
In our Quarterly Review, we bring you important UK developments relating to business crime, investigations and regulatory enforcement from the last three months. We commented last month that the scale of the impact of the...more
- As of 1:00 p.m. BST July 6, 2020, the GHR Regulation came into force, representing the introduction of the U.K.’s long awaited GHR Regime. - The GHR Regime is the first standalone U.K. sanctions regime to be in current...more
HM Treasury has published the Sanctions (EU Exit) (Miscellaneous Amendments) Regulations and the Sanctions (EU Exit) (Miscellaneous Amendments) (No. 2) Regulations, amending certain aspects of the U.K. sanctions regime. The...more
Should the UK leave the EU without any new deal being put in place, or come to the end of any implementation period following the UK’s exit without further agreement, the UK will look to re-establish all of the EU sanctions...more
Customer due diligence is a familiar phrase for many. But at a time when money laundering is estimated to represent between 2 - 5% of GDP globally, customer due diligence is set to change and the UK Government is at the...more
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