No one size fits all When dealing with sanctions enforcement authorities in investigations, companies should have a clear understanding of an investigating agency’s expectations. These can be tricky to navigate in the current enforcement environment where multiple agencies across several jurisdictions are often actively investigating similar conduct. To compound the situation and risks, those agencies may take different approaches to communicating with a company, obtaining information or evidence from the target and third parties, and…
On 20 February 2024, the financial intelligence agencies of Canada (FINTRAC), Germany (FIU DE) and the Netherlands (FIU-NL) released a joint advisory regarding illegal procurement of dual-use goods by Russian end-users (Joint Advisory). Although primarily addressed to entities reporting under each country’s respective anti-money laundering (AML) regime, the Joint Advisory also is a useful resource for other companies seeking to comply with sanctions and export controls more generally, as it seeks to provide additional guidance…
On 18 December 2023, the EU published its 12th package of sanctions targeting Russia. The changes implemented in this package have a material impact on all businesses with a continued or residual presence in Russia, including those seeking to exit and divest from Russia. Moreover, all companies, even those not trading directly with Russia, should be mindful of the increased focus on targeting circumvention.In our latest on-demand webinar, we provide you with an overview of some…
On 18 July 2023, the Dutch Fiscal Intelligence and Investigation Service (FIOD) published a statement that it had recently arrested a Dutch citizen in an ongoing investigation into suspected circumvention of EU sanctions against Russia. As part of the investigation, the FIOD also seized the business inventory and digital and physical administration of the suspect and his company. The arrested individual is suspected of exporting computers and computer parts to Russia in violation of EU sanctions.…