On 7 January 2025, the UK’s Office of Trade Sanctions Implementation (“OTSI”) published two guidance documents on compliance with the UK’s sanctions against Russia, focusing on combatting sanctions evasion and on incorporating “no Russia” clauses in customer contracts. The new guidance documents aim to support UK businesses in understanding and mitigating the risks associated with Russian sanctions evasion, by providing guidance on understanding circumvention practices and recommendations for mitigation steps, including incorporating protective “no Russia”…
In October 2024, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and the United Kingdom’s Office of Financial Sanctions Implementation (“OFSI”) celebrated the second anniversary of their Enhanced Partnership. This collaboration, initiated in response to the increasingly complex geopolitical landscape, aims to bolster the effectiveness of sanctions as a global tool for national security. Over the past two years, OFAC and OFSI have worked closely to coordinate their sanctions regimes,…
On 12 September, the UK Government announced new powers for the civil enforcement of trade sanctions pursuant to the Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024, the “Trade Enforcement Regulations”). From 10 October 2024, the Government will be able to impose penalties of up to GBP 1 million or 50% of the value of breaches of trade sanctions (whichever is greater) in relation to certain breaches of UK trade sanctions. The new powers…
Companies caught in the eye of the sanctions enforcement storm can only begin to effectively weather it by conducting a thorough internal investigation. These investigations are multifaceted (see our other blog posts in this series here), but an essential component is often conducting interviews. Interviews are a fundamental part of cross-border sanctions investigations that combine practical and legal challenges. Organizing them effectively requires an appreciation of practices in different jurisdictions, including local laws, customs, and…