The winds of change continue to swirl in the world of international sanctions enforcement. Governments around the globe are imposing new sanctions at a rapid pace and ramping up their efforts to crack down on violations. At Baker McKenzie, the Global Sanctions Investigations Group understands that navigating the ever-evolving sanctions landscape can feel like walking a tightrope. One misstep and your company could be facing material fines, reputational damage, and even criminal charges. That’s why…
The UK Office of Financial Sanctions Implementation (“OFSI”) and the Foreign, Commonwealth and Development Office (“FCDO”) have issued joint guidance (“Joint Guidance”) on the application of the UK’s “ownership and control” test under financial sanctions legislation in circumstances involving designation of public officials. The Joint Guidance follows a significant amount of debate in relation to these issues, following the Court of Appeal’s recent judgment in the case Mints v PJSC National Bank Trust [2023] EWCA…
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,…