At the Annual Compliance conference recently held in London, Baker McKenzie hosted a session on ‘The evolving national security, sanctions and export controls landscape’. This session introduced the concept of the “trade toolbox” — a growing set of measures designed to manage national security risks through trade and investment restrictions. Speakers highlighted the increasing complexity of global compliance, particularly in relation to business relating to China, Russia, and in the Middle East. China: outbound investment,…
On 21 March 2025, the UK Office of Financial Sanctions Implementation (“OFSI”) published its 2023-2024 annual review (see here). The report summarises OFSI’s activities for the 2023-24 financial year in the context of its aim to “Engage, Enhance, Enforce”. This involves industry engagement to improve understanding of UK sanctions, enhancing stakeholder service through increased hiring and investment, and enforcing compliance using a full range of actions and improved processes. Although OFSI’s report indicates that the…
Earlier this year, the EU introduced various new restrictions as part of its sanctions packages targeting Russia (see our blog post on the 14th EU Russia sanctions package) and Belarus (see our blog post of the most recent EU Belarus sanctions package). Among the notable and novel restrictions were: Businesses should therefore review their current practices and consider whether any enhancements are necessary to comply with these measures. Guidance on “best efforts” obligations The “best…
On 14 November 2024, the UK government introduced a number of changes to its sanctions regulations through the Sanctions (EU Exit) (Miscellaneous Amendments) (No.2) Regulations 2024 (the “Amending Regulation”). See here for the Amending Regulation and here for the blog post from the Office of Financial Sanctions Implementation (“OFSI”) summarising the changes. The Amending Regulation introduces several important changes to existing UK sanctions legislation, primarily in respect of the UK’s financial sanctions framework. The UK…