The UK Financial Conduct Authority (“FCA”) has recently published proposed changes to its Financial Crime Guide (available here). The Financial Crime Guide sets out the FCA’s expectations for how financial institutions should approach compliance across a range of financial crime areas, and includes examples of what the FCA considers to be good and bad practice. The guide makes clear that firms “should apply the guidance in a risk-based, proportionate way taking into account such factors…
On 8th July 2026, the UK enacted the National Security (State Threats) Act 2026 (the new “Act”), introducing a new power for the Home Secretary to designate bodies involved in foreign power threat activity and creating criminal offences for supporting, assisting, or obtaining a material benefit from those bodies. The new regime is intended to address a perceived gap between sanctions, terrorism legislation and the existing National Security Act 2023 framework, by targeting organisations, proxies…
On June 23, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and HM Treasury’s Office of Financial Sanctions Implementation (“OFSI”) published a joint statement reflecting on their latest Enhanced Partnership exchange and issued a new joint guidance document that provides a comparative overview of the US and UK sanctions regimes. The joint statement and guidance follow a January 2026 in-person meeting between OFSI and OFAC. The statement and accompanying guidance…
On 9 June 2026, European Commission President Ursula von der Leyen announced that the European Commission is preparing a 21st sanctions package against Russia, marking a further step in the EU’s ongoing effort to intensify economic pressure following Russia’s continued aggression in Ukraine. The proposed measures focus on high-impact sectors, including energy, financial services (including crypto-assets) and trade restrictions. Key Elements of the Proposed 21st Package Energy and Transport: Expanded Targeting of the Shadow Fleet…