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Tristan Grimmer

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The UK Government has introduced new economic, trade and transport sanctions on Belarus, extending existing Russia sanctions measures to Belarus in certain areas. These are included in The Republic of Belarus (Sanctions) (EU Exit) (Amendment) Regulations 2022 and entered into force on 5 July. The main changes introduced by the relevant legislation include: Expanded powers for designation, including: Addition of power to designate persons by description Expansion of criteria for designation to include: conduct destabilising…

What are the main changes: For breaches of financial sanctions that are committed after 15 June 2022, OFSI will be able to impose civil monetary penalties on a strict civil liability basis. This means that going forward OFSI will not have to prove that a person had knowledge or reasonable cause to suspect that they were in breach of financial sanctions. OFSI will continue to have the burden of proving that the financial sanctions breach…

The National Security and Investment Act (“NSI Act”) came into force this week, completing the overhaul of the UK’s foreign investment rules and creating a standalone foreign investment screening regime. The new rules require businesses and investors to submit mandatory notifications for certain acquisitions of and investments in companies operating in 17 key sectors. The rules also grant the UK Government extensive powers to investigate and impose conditions on a wide range of transactions, including…

On 23 June 2021, HM Treasury released updated guidance on financial and investment restrictions under the Russia (Sanctions) (EU Exit) Regulations 2019 (the “Regulations”). Whilst the guidance is substantively the same as that released in June 2020, a number of “Frequently Asked Questions” have been added to clarify interpretation of the Regulations. The Frequently Asked Questions reflect some, though not all, of the guidance previously outlined by the European Commission in relation to its interpretation…