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Julian Godfray

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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…

The US and UK introduced new prohibitions last month related to Russian-origin aluminum, copper, and nickel produced on or after April 13, 2024. The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued two determinations imposing new restrictions on the importation of Russian-origin aluminum, copper, and nickel produced on or after to April 13, 2024 (the “Covered Russian Metals”) into the United States, and on the provision by US persons or within…

On April 18, 2024, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) and the UK’s Foreign, Commonwealth & Development Office (“FCDO”) announced a coordinated sanctions package targeting Iran. In the US, OFAC added 16 individuals and 10 entities to the Specially Designated Nationals and Blocked Persons List (“SDN List”) and the US Commerce Department’s Bureau of Industry and Security (“BIS”) also expanded the scope of Foreign Direct Product (“FDP”) rules for foreign-produced items…

On 4 March 2024, the UK Foreign, Commonwealth and Development Office (“FCDO”) published a Post-Legislative Scrutiny Memorandum (the “Memorandum”) for the UK Sanctions and Anti-Money Laundering Act 2018 (“SAMLA”). The Memorandum (available here) provides an assessment of the functioning of SAMLA and UK sanctions regimes underpinned by SAMLA, following the UK’s introduction of an autonomous sanctions framework post-Brexit. The Memorandum covers a broad range of areas relating to SAMLA and the UK’s sanctions framework, including…