Introduction On 22 July 2025, the UK Office of Financial Sanctions Implementation (“OFSI”), which is responsible for the enforcement of financial sanctions in the UK, opened a public consultation on proposed amendments to its civil monetary penalty procedures. The consultation (available here) seeks input on five key categories of amendments to OFSI’s current civil enforcement processes as follows: Responding to the consultation The deadline to provide responses to the consultation is 23:59 London time on…
Geopolitical and geoeconomic tensions between China and the US remain high. This session explored the use of export control and other national security measures by competing regimes, drawing on perspectives from the US, China, the EU, the UK, Japan, and Taiwan. The session began with an overview of US national security policies towards China and recent efforts to regulate the flow of capital and data. This was followed by insights from China on retaliatory measures,…
From 14 May 2025, certain additional businesses are now subject to mandatory sanctions reporting obligations as changes to the definition of “relevant firms” for financial sanctions reporting purposes come into force. Consequently, High Value Dealers (HVDs), Art Market Participants (AMPs), Letting Agents and Insolvency Practitioners are now legally required to report to OFSI whether they have knowledge or reasonable cause to suspect the presence of sanctioned parties, or suspected financial sanctions breaches. These obligations were…
On January 10, 2025, in a multilateral sanctions action, the US, Canada, EU, and UK sanctioned various Venezuelan individuals linked to the Venezuelan government and prominent state-owned entities. US Sanctions The US Treasury Department’s Office of Foreign Assets Control (“OFAC”) designated eight Venezuelan individuals as Specially Designated Nationals pursuant to Executive Order 13692, including the president of the Specially Designated National state-owned petroleum company, Petroleos de Venezuela, S.A., (PdVSA), the Venezuelan Ministry of Transportation and…