On 31 July 2025, the UK Office of Financial Sanctions Implementation (“OFSI”) announced that it had imposed a monetary penalty totalling GBP 300,000 on Markom Management Limited (“MML”), a provider of fiduciary, management, administration, bookkeeping and accounting services incorporated in the UK. The monetary penalty related to conduct in 2018 and a breach of the UK’s pre-Brexit sanctions regime, specifically the UK’s implementing regulations for Council Regulation (EU) No 269/2014 (Ukraine Misappropriation and Human Rights)…
Emphasis on protecting US business, economic and national security interests In brief During a May 12 speech and in a newly issued Criminal Division White-Collar Enforcement Plan (the “Plan”), the Head of the US Department of Justice (DOJ)’s Criminal Division, Matthew R. Galeotti, set out the Department’s priorities for corporate criminal enforcement under the new Administration and issued a number of updated policy documents. These changes affect the Criminal Division’s Corporate Enforcement and Voluntary Self-Disclosure…
On March 25, 2025, the Spanish Council of Ministers approved a draft bill to implement Directive (EU) 2024/1226 on the definition of criminal offenses and penalties for the violation of Union restrictive measures and amending Directive (EU) 2018/1673 (“Draft Bill” and “Directive”, respectively). The Directive established minimum Member State requirements concerning the definition of criminal offenses and penalties for the violation and circumvention of EU sanctions. For further detail on the Directive, see our blog post…
On 24 September 2024, the G7 Sub-Working Group on Export Control Enforcement, which comprises representatives from the United States, Canada, France, Germany, Italy, Japan, the United Kingdom, and the European Union (the “G7”), published the first-ever joint guidance for industry on preventing evasion of export control and sanctions imposed on Russia (“Joint Guidance”). The stated goal of the Joint Guidance is to assist industry in identifying Russia’s evolving evasion tactics and in complying with multilateral…