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Sven Bates

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On 9 September the Financial Conduct Authority (“FCA”) and the Prudential Regulation Authority (“PRA”) published a letter to bank CEOs with the purpose of reiterating expectations of firms when undertaking trade finance activities. The Dear CEO letter addressed both conduct and prudential issues where the regulators consider that improvements are required in firms’ controls. The regulators stressed that “firms need to demonstrate that they have taken a risk sensitive approach to their control environment that…

On 5 August 2021, the Office of Financial Sanctions Implementation (“OFSI”) imposed a GBP 50,000 penalty on TransferGo Limited (“TransferGo”), a UK FinTech company, for breaching UK sanctions when it issued instructions to make payments to accounts held at the Russian National Commercial Bank (“RNCB”), a designated party. Between 20 March 2018 and 18 December 2019, TransferGo issued instructions to make 16 payments into accounts held at RNCB, the total value of which was…

On 12 January 2021, UK Foreign Secretary Dominic Raab announced new measures to ensure that UK companies are neither complicit in, nor profit from, alleged human rights violations in Xinjiang, China. See press release here. Under the new measures, the UK will review export controls in order to prevent exports of goods potentially contributing, either directly or indirectly, to alleged human rights abuses in Xinjiang. This review will determine specific items that will become subject…

On 28 July 2020, the EU agreed to impose EU-wide measures to restrict the export of certain items to Hong Kong. The EU Council’s press release can be found here. These restricted goods include equipment or technology that could be used for internal repression, interception of internal communications or cyber surveillance. Like recent US and UK measures, the new EU export controls have been proposed in response to the recent HK National Security Law. Germany…