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Ross L. Denton

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The UK Office of Financial Sanctions Implementation (OFSI) has published an updated version of its guidance on monetary penalties for breaches of financial sanctions (the “Monetary Penalties Guidance”). The Monetary Penalties Guidance was first issued in April 2017 and sets out guidance on the circumstances in which OFSI may consider it appropriate to impose a monetary penalty, and how it will determine the amount of the penalty. No changes of policy on monetary penalties were…

The European Commission has started the process by which it would add US sanctions measures on Iran to the so-called Blocking Regulation (formerly Regulation 2271/96). This is in direct response to the US President’s withdrawal of his waiver relating to the JCPOA. The effect of the withdrawal was to reintroduce US sanctions that were in force prior to the JCPOA. US sanctions on Iran not only impact US companies and persons, but can, in certain…

Last week, the Office of Financial Sanctions Implementation (OFSI) launched new guidance to cover questions relevant to those importing and exporting goods and services, particularly for those operating where financial sanctions are in force. Link here: OFSI Import/Export FAQs This guidance should be read alongside the OFSI’s Financial Sanctions Guidance. Link here: OFSI General Guidance The guidance considers various types of sanctions, including arms embargoes, trade sanctions and financial sanctions detailing what actions are taken…

HR/VP Federica Mogherini met with the Foreign Ministers of France (Jean-Yves Le Drian), Germany (Heiko Maas), the United Kingdom (Boris Johnson) and of the Islamic Republic of Iran (Mohammad Javad Zarif) on 15 May 2018, in two separate meetings, to discuss our common lines and the work ahead of us, following the announcement made by the United States of its withdrawal from the Joint Comprehensive Plan of Action (JCPOA), the Iran nuclear deal. They recalled their commitment…