On March 31, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a Sanctions Advisory to raise awareness of potential sanctions risks arising from sham transactions used to evade sanctions. The advisory presents examples and lists red flags that may indicate the presence of a sham transaction. While it is explanatory only and does not have the force of law, the advisory follows several recent enforcement actions involving blocked persons…
On 5 September 2024, the UK amended the scope of its Russia sanctions relating to the provision of certain legal advisory services to non-UK persons, as contained in Regulations 54D and 60DB of The Russia (Sanctions) (EU Exit) Regulations 2019 (“UK Russia Regulations”), via The Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2024 (the “Amending Regulation”). The Amending Regulation entered into force on 6 September 2024, in short (i) clarifying the knowledge a person must have…
On 18 July 2023, the Dutch Fiscal Intelligence and Investigation Service (FIOD) published a statement that it had recently arrested a Dutch citizen in an ongoing investigation into suspected circumvention of EU sanctions against Russia. As part of the investigation, the FIOD also seized the business inventory and digital and physical administration of the suspect and his company. The arrested individual is suspected of exporting computers and computer parts to Russia in violation of EU sanctions.…