On 20 February 2024, the financial intelligence agencies of Canada (FINTRAC), Germany (FIU DE) and the Netherlands (FIU-NL) released a joint advisory regarding illegal procurement of dual-use goods by Russian end-users (Joint Advisory). Although primarily addressed to entities reporting under each country’s respective anti-money laundering (AML) regime, the Joint Advisory also is a useful resource for other companies seeking to comply with sanctions and export controls more generally, as it seeks to provide additional guidance…
On 18 December 2023, the EU published its 12th package of sanctions targeting Russia. The changes implemented in this package have a material impact on all businesses with a continued or residual presence in Russia, including those seeking to exit and divest from Russia. Moreover, all companies, even those not trading directly with Russia, should be mindful of the increased focus on targeting circumvention.In our latest on-demand webinar, we provide you with an overview of some…
On December 22, 2023, the Biden Administration issued a new Executive Order (“EO”) “Taking Additional Steps with Respect to the Russian Federation’s Harmful Activities” (the “December 22 EO”) amending EO 14024 of April 15, 2021 (“Blocking Property With Respect To Specified Harmful Foreign Activities of the Government of the Russian Federation”) and EO 14068 of March 11, 2022 (“Prohibiting Certain Imports, Exports, and New Investment With Respect to Continued Russian Federation Aggression”). According to a…
On 14 December 2023, the Office of Financial Sanctions Implementation (“OFSI”) published its 2022-2023 annual review (see here). The review summarises OFSI’s activities over the 2022-2023 financial year and looks ahead at trends and OFSI’s priorities for the next year. Russia Sanctions The report has a particular focus on the UK’s expanded Russia sanctions regime, stating that by 31 March 2023, “130 oligarchs and family members” who had a combined net worth of around £145…