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Julian Godfray

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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”)…

On 14 December 2023, the UK Government introduced two regulations (The Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2023 and The Russia (Sanctions) (EU Exit) (Amendment) (No. 5) Regulations 2023) amending The Russia (Sanctions) (EU Exit) Regulations 2019 to impose further restrictions on goods, technology, and sources of funding that the UK Government considers could support Russia’s war against Ukraine. The majority of the amendments came into force on 15 December 2023; however a…

On 1 December, it was announced that the UK Office of Financial Sanctions Implementation (“OFSI”) and the UK Financial Conduct Authority (“FCA”) had entered into a memorandum of understanding (“MOU”) on 21 November 2023 which outlines the agencies’ agreement to co-operate and share information relating to suspected or actual sanctions breaches with each other. This MOU replaces a previous MOU that had been in place since April 2019. In summary, under the MOU it has…

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…