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Sanctions Regimes

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UK Financial Conduct Authority publishes report indicating that financial institutions must do more to prevent sanctions breaches: key takeaways

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On 28 May 2026, the UK Financial Conduct Authority (“FCA”) published a detailed report outlining steps that financial institutions take to comply with sanctions requirements, including examples of good and poor practice. The report addresses both financial and trade sanctions measures, with financial institutions managing risks arising from their own activities and those of their customers. The report follows the FCA’s engagement with over 150 FCA-supervised firms since February 2022, and builds upon the FCA’s…

Swiss Federal Supreme Court clarifies the evidentiary threshold triggering asset freeze and reporting obligations under Art. 15 para. 1 and Art. 16 para. 1 of the Ukraine Ordinance

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Judgment 4A_537/2025 of 28 April 2026 In its recent judgment 4A_537/2025 of 28 April 2026, the Swiss Federal Supreme Court upheld the judgment of the Commercial Court of the Canton of Zurich of 17 September 2025 (HG230210-O) and provided important guidance on the interpretation of Swiss sanctions laws – specifically on the asset freeze and reporting obligations imposed on financial institutions holding or managing funds. The Swiss Federal Supreme Court clarified, first, the evidentiary threshold…

Swiss Government partially implements the 20th EU sanctions package

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On 22 May 2026, the Swiss Federal Council announced the expansion of its sanctions lists against Russia and Belarus (see press release here). With this step, Switzerland has partially implemented the measures adopted by the EU under its 20th sanctions package. The corresponding amendments to the Ordinance on Measures in Connection with the Situation in Ukraine (“Ukraine Ordinance”) and the Ordinance on Measures against Belarus (“Belarus Ordinance”) entered into force on 22 May 2026. Following…

UK Expands Russia Sanctions Regime and Issues New General Licences for LNG Maritime Transportation and Processed Oil Products

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On 19 May 2026, the UK Government published the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2026 (SI 2026/543) (the “Amendment Regulations”), introducing numerous amendments to the Russia (Sanctions) (EU Exit) Regulations 2019 (the “Regulations”). The Amendment Regulations introduce certain new trade prohibitions and expand existing controls across the Russia sanctions regime. The Amendment Regulations come into force on 20 May 2026 and, in short, include: Supplementing this, the Office of Trade Sanctions Implementation (“OTSI”) issued…

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