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Sunny Mann

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Earlier in December 2021, the UK Government announced a package of new measures with the aim of updating the export control regime in the UK. In particular, this includes the following aspects: i. New Strategic Export Licensing Criteria A revised version of the licensing criteria for strategic export controls has been laid before Parliament (known as the Strategic Export Licensing Criteria). This will be applied with immediate effect, and will impact all licensing decisions as…

On 15 December 2021, the European Parliament adopted a resolution on the challenges and prospects for multilateral weapons of mass destruction arms control and disarmament regimes. The resolution calls for the EU to play a strong role, and for member states to show continuous support, in all major disarmament treaties and non-proliferation regimes. The resolution states that renewed global arms control and disarmament efforts are essential to the EU’s security, amid concerns that key arms…

Financial institutions face an increasingly complex sanctions compliance environment. Sanctions are increasingly emerging at the forefront of compliance agendas given the proliferation of new restrictions and counter-measures, together with increasingly aggressive enforcement action extra-territorially. This is impacting both financial institutions and their clients, leading to expectations for more robust compliance programs for both. This has been acutely felt most recently in the Middle East following the USD 100 million sanctions fine against a Dubai based…

On 14 October 2021, the Office of Financial Sanctions Implementation (“OFSI”) published its Annual Review, providing an overview of OFSI’s activities in the financial year April 2020 to March 2021. A copy of the Annual Review is available here. Statistics In 2020-2021, OFSI considered 132 reports of potential financial sanctions breaches, a slight decrease from 140 in 2019-2020. However, the number of cases considered generally remains on an upwards trajectory from the 99 potential financial sanctions…