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…
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…
In recent weeks, there have been a number of noteworthy developments highlighting the increasing focus that US, EU, UK and other governments are placing on the potential circumvention of sanctions against Russia, and the roles of third countries and companies in facilitating the circumvention or undermining of such sanctions measures. These anti-circumvention efforts are taking place in the context of the G7’s concerted effort to bolster sanctions enforcement around the world, through the creation of…
The UK has announced a new package of sanctions against Russia. This will include the following sanctions: Export bans on every item Russia has been found using on the battlefield to date. Goods will include aircraft parts, radio equipment, and electronic components that can be used by the Russian military industrial complex, including in the production of UAVs. Import bans on 140 goods including iron and steel products processed in third countries. Extension of existing…