On 5 October 2018, the Office of Financial Sanctions Implementation (“OFSI”) published its first Annual Review, providing an overview of OFSI’s activities in the financial year 2017 to 2018, as well as noting its priorities for the future. In 2017-18, OFSI received 122 reports of suspected breaches of financial sanctions, with a reported value of around £1.35 billion. OFSI uses ‘reports received’ as a first approximation snapshot of non-compliance in a given period. It is…

Further to our previous blog posts of 18 May 2018 and 7 June 2018, the updated Blocking Regulation (Regulation 2271/96) entered into force on 7 August 2018.  The effect is to block the application in the EU of extraterritorial U.S. sanctions targeting Iran. The update was triggered by the U.S.’ unilateral decision on 8 May 2018 to withdraw from the Joint Comprehensive Plan of Action, and the subsequent reimposition of extraterritorial sanctions. The full list…

In July 2018, the Control of Economic Activity (Occupied Territories) Bill 2018 (the “Bill”, available here), a Private Member’s Bill proposed by the Irish independent senator Frances Black, was passed in the Seanad (the Upper House of the Irish Parliament). The Bill makes it an offence for a person to import or sell goods or services originating in an occupied territory or to extract resources from an occupied territory in certain circumstances. Although the Bill…

On 16 July 2018, the EU adopted a framework (Council Regulation (EU) 2018/1001; Council Decision (CFSP) 2018/1006) to impose targeted sanctions (travel bans and asset freezes) against persons and entities who are responsible for “undermining the rule of law or obstructing an inclusive political solution in the Maldives”, as well as those responsible for “serious human rights violations or abuses”. The relevant EU press release on this framework can be found here. This framework is…