The UK Office of Financial Sanctions Implementation (āOFSIā) and the Foreign, Commonwealth and Development Office (āFCDOā) have issued joint guidance (āJoint Guidanceā) on the application of the UKās āownership and controlā 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 Appealās recent judgment in the case Mints v PJSC National Bank Trust [2023] EWCA…
The UKās 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,…
The G7 announced the creation of a new Enforcement Coordination Mechanism “to bolster compliance and enforcement of our measures and deny Russia the benefit of G7 economies” on the one-year anniversary of Russia’s invasion of Ukraine. As set out in our introduction to the blog series, our sanctions experts in G7 offices will respond to a series of questions relating to sanctions enforcement and the potential impact of the Enforcement Coordination Mechanism. Following our…
The UK has adopted The Russia (Sanctions) (EU Exit) (Amendment) (No. 16) Regulations 2022 which introduce new restrictions against Russia and expand existing ones. The Legislation enters into force on 5 December 2022. The Russia (Sanctions) (EU Exit) (Amendment) (No. 16) Regulations 2022: Prohibit the direct or indirect supply or delivery by ships of certain oil and oil products falling within commodity codes 2709 and 2710, from a place in Russia to a third country, or from one…