The UK Office of Financial Sanctions Implementation (“OFSI”) and the Foreign, Commonwealth and Development Office (“FCDO”) have issued joint guidance (“Joint Guidance”) on the application of the UK’s “ownership and control” test under financial sanctions legislation in circumstances involving designation of public officials. The Joint Guidance follows a significant amount of debate in relation to these issues, following the Court of Appeal’s recent judgment in the case Mints v PJSC National Bank Trust [2023] EWCA…
The UK’s Office of Financial Sanctions Implementation (“OFSI”) has published updated guidance (the “Russia Sanctions Guidance”) on the implementation of the Russia (Sanctions) (EU Exit) Regulations 2019 (“UK Russia Regulations”), including a new FAQ addressing circumstances where a UK financial institution receives funds indirectly from or via a designated bank. In parallel with this update to its Russia Sanctions Guidance, OFSI has also published a new General Licence relating to Correspondent Banking Payments (INT/2023/3566356). Updated…
The UK, France and Germany (the European signatories to the Joint Collective Plan of Action (“JCPOA”) nuclear deal with Iran in 2015, referred to as the “E3”) have decided to retain certain sanctions previously imposed upon Iran. The press release published by the E3 announcing this decision is available here. The JCPOA was agreed in 2015 between the E3/EU+3 (China, France, Germany, the Russian Federation, the United Kingdom and the United States, with the EU’s…
Following reports in August (see blog post here), on 6 September, the UK government formally announced the proscription of the Wagner Group. Parliament has passed an order, presented by the Home Secretary, to proscribe the Wagner Group under the Terrorism Act 2000. On 15 September, the order came into force, making it a criminal offence to belong to, encourage support for, assist or use the logo of the Wagner Group. Furthermore, the Wagner Group’s assets…