The sanctions enforcement storm is underway. As we highlighted in the introduction to this blog series, the quickly evolving sanctions landscape of recent years has increased the complexity of compliance. Keeping up with ever-changing multi-jurisdictional sanctions and adapting compliance practices has proven challenging for companies with complex operations and supply chains. Instances of non-compliance can be inevitable. A company’s investigation triage plan should evaluate mandatory disclosure obligations and, if there are none, the availability and…
In January this year, we reported on substantial proposed changes to the Defence Trade Control Act 2012 (“DTC Act”) that would require businesses handling Defence and Strategic Goods List (“DSGL”) subject matter within and from Australia to implement enhanced compliance mechanisms. On 27 March 2024, the Australian federal parliament implemented these proposed changes by passing the Defence Trade Controls Amendment Act 2024 (“Amendment Act”). The bulk of the changes to the DTC Act will commence no later than 8…
The leader of Russia’s political opposition, Alexei Navalny, died in a Siberian prison on February 16, just over a week before the two-year anniversary of Russia’s full-scale invasion of Ukraine on February 24. Both Navalny’s death and the anniversary of the invasion were cited as the motivations behind the latest rounds of sanctions against Russia. Members of our global sanctions team in our offices in the US, UK, Sweden, Australia, and Canada summarize the latest…
On January 22, 2024, the United States, United Kingdom, and Australia announced an additional round of coordinated sanctions designations of individuals, entities, and aircraft linked to Hamas and the Palestinian Islamic Jihad (“PIJ”). This coordinated action builds on recent joint US-UK and unilateral US designations. Our prior blog post on the October 18, 2023 US designations is available here. US Sanctions On January 22, 2024, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”)…