On 14 June 2023, the UK Office of Financial Sanctions Implementation (“OSFI”) published updated guidance for the Maritime Services Ban and Oil Price Cap (the “Updated Guidance”). The Updated Guidance can be found here and our previous blog posts on UK Maritime Services Ban and Oil Price Cap can be found here and here. The Updated Guidance provides additional clarity and detail on the following: Wind-down periods: OFSI has introduced a 45-day wind-down period for…
On 20 June 2023, the UK enacted additional amendments to The Russia (Sanctions) (EU Exit) Regulations 2019 (“Russia Regulations”) through The Russia (Sanctions) (EU Exit) (Amendment) (No. 2) Regulations 2023 (the “Amendment”). The Amendment makes two principal changes to the Russia Regulations by: expanding the “purpose” for which the Russia Regulations are imposed to include the promotion of compensation payment for damage, loss or injury suffered by Ukraine; and expanding the definition of “non-government controlled…
As discussed in our recent blog post (available here), the UK Office of Financial Sanctions Implementation (“OFSI”) has updated its guidance on enforcement and monetary penalties for breaches of financial sanctions (the “Monetary Penalties Guidance”, available here), to include a number of paragraphs setting out OFSI’s expectations around the nature and type of due diligence that companies should undertake when assessing whether an entity is owned or controlled by one or more designated persons, for sanctions…
The UK Office of Financial Sanctions Implementation (“OFSI”) has updated its guidance on enforcement and monetary penalties for breaches of financial sanctions (the “Monetary Penalties Guidance”, available here), to include a number of paragraphs setting out OFSI’s expectations around the nature and type of due diligence that companies should undertake when assessing whether an entity is owned or controlled by one or more designated persons, for sanctions purposes. This update to the Monetary Penalties Guidance…