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Andrew Rose

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The UK Office of Financial Sanctions Implementation (“OFSI”) has updated its guidance on enforcement and monetary penalties for breaches of financial sanctions (the “Monetary Penalties Guidance”, available here), to include a number of paragraphs setting out OFSI’s expectations around the nature and type of due diligence that companies should undertake when assessing whether an entity is owned or controlled by one or more designated persons, for sanctions purposes. This update to the Monetary Penalties Guidance…

The UK has adopted The Russia (Sanctions) (EU Exit) (Amendment) (No. 17) Regulations 2022 . See here for explanatory memorandum accompanying this legislation. Updated guidance on Russia Sanctions has been published in order to reflect the changes introduced by the latest legislation. The new legislation introduces and expands on current trade and financial sanctions and comes into force on Friday, 16 December 2022. Trade sanctions Prohibits the direct and indirect provision of the following additional…

On 2 March 2022, the EU significantly expanded its sanctions against Belarus, in response to Belarus’ role in the ongoing crisis in Ukraine. Belarus was already subject to significant EU sanctions targeting its financial, dual-use, military, tobacco, petroleum and potash sectors, many of which were imposed following the Belarusian Government’s response to civil unrest following the 2021 election (see our previous post here). Many of the changes are in line with sanctions imposed against Russia…

On March 1 and 2, 2022, the UK published four Regulations which introduce new financial, trade and shipping sanctions against Russia. New financial sanctions The Russia (Sanctions) (EU Exit) (Amendment) (No. 2) Regulations 2022 introduce the following restrictions: Prohibition on dealing with securities or money-market instruments issued by, or providing loans/credit to a person connected with Russia (including Russian incorporated entities and residents) or the Russian Government. The aforementioned prohibitions also apply to all entities…