Having focused on the enforcement of sanctions by the United States, United Kingdom and the European Union in the past weeks, this week we will take a closer look at the current enforcement practice of the German authorities and the changes to be expected following the newly announced G7 Enforcement Coordination Mechanism. What are the recent sanctions enforcement trends in Germany? We note that the enforcement of the EU sanctions, particularly against Russia, is taken…
The UK Office of Financial Sanctions Implementation (“OFSI”) has updated its guidance on enforcement and monetary penalties for breaches of financial sanctions (the “Monetary Penalties Guidance”, available here), to include a number of paragraphs setting out OFSI’s expectations around the nature and type of due diligence that companies should undertake when assessing whether an entity is owned or controlled by one or more designated persons, for sanctions purposes. This update to the Monetary Penalties Guidance…
On March 10, 2023, Canada amended the Special Economic Measures (Russia) Regulations (the “Regulations”) to prohibit the import, purchase and acquisition of steel and aluminum goods listed under Schedule 11 from Russia or from any person in Russia. This amendment applies to any person in Canada and any Canadian outside Canada and was entered into force on March 10, 2023. The steel goods listed under Schedule 11 of the Regulations include sheet piling, railway or…
The G7 announced the creation of a new Enforcement Coordination Mechanism “to bolster compliance and enforcement of our measures and deny Russia the benefit of G7 economies” on the one-year anniversary of Russia’s invasion of Ukraine. As set out in our introduction to the blog series, our sanctions experts in G7 offices will respond to a series of questions relating to sanctions enforcement and the potential impact of the Enforcement Coordination Mechanism. Following our…