A company’s Russia-bound shipment gets stopped by customs authorities in the UK, which claim the products are prohibited for export to Russia. After confirming that the products are indeed restricted, the company initiates an internal investigation to get to the root cause of the problem and remediate. A whistleblower uses its employer’s compliance hotline to report concerns about possible US, EU, and UK sanctions or export controls violations. The company initiates an internal investigation to…
On February 1, 2024, President Biden issued Executive Order 14115 (“EO 14115”) targeting persons involved in activities that threaten the peace, security, and stability in the West Bank. Meanwhile, the UK government announced on 12 February 2024 sanctions on “extremist Israeli settlers” who have committed human rights abuses against Palestinian communities. Pursuant to EO 14115, four individuals were added to the Specially Designated Nationals and Blocked Persons List (“SDN List”). Concurrently, the US Treasury Department’s…
The UK’s Financial Conduct Authority (FCA) plays a key role in monitoring how UK-regulated financial institutions guard against financial crime risks, and how effectively they implement financial crime policies and procedures. In recent months, as the UK and other governments have placed increasing focus on preventing the circumvention of sanctions targeting Russia, the FCA has taken a number of steps to emphasise its focus on how financial institutions are complying with financial and trade sanctions,…
On 14 June 2023, the UK Office of Financial Sanctions Implementation (“OSFI”) published updated guidance for the Maritime Services Ban and Oil Price Cap (the “Updated Guidance”). The Updated Guidance can be found here and our previous blog posts on UK Maritime Services Ban and Oil Price Cap can be found here and here. The Updated Guidance provides additional clarity and detail on the following: Wind-down periods: OFSI has introduced a 45-day wind-down period for…