On 21 February, the UK Office of Financial Sanctions Implementation (“OFSI”), announced that it had issued a monetary penalty totaling GBP 36,393.45 to Clear Junction Limited (“Clear Junction”), a provider of payment services. This penalty follows (and is associated with) OFSI’s earlier GBP 50,000 penalty against TransferGo, announced in August 2021 (see our previous blog post here). The monetary penalty related to 15 transactions made to accounts held by non-sanctioned parties with the Russian National…
As reported by the FT yesterday (26 January 2022, article available here), the ECB has warned European lenders of the potential risks they will face, should further sanctions be imposed against Russia in the event of an invasion of Ukraine. The impact of any sanctions would not be limited to Russian financial institutions/businesses but is likely to be felt across the world, especially by financial institutions who have significant Russian exposure. The FT reported that…
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 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…