The Middle East is an increasingly important jurisdiction for Western governments from a Russia sanctions foreign policy perspective, as there is a perception that increased trade flows between the Middle East and Russia means that Western sanctions are effectively being circumvented. Companies in the Middle East may have concerns about triggering EU / UK / US sanctions jurisdiction, or being directly designated by Western governments for engaging in activities deemed to be contrary to the…
On 13 June 2024, the Office of Financial Sanctions Implementation (OFSI) expanded its Consolidated List, which provides details of individuals and legal entities designated under the Russia (Sanctions) (EU Exit) Regulations 2019 (S.I. 2019/855). There are 42 new entries added to the Consolidated List which are now subject to an asset freeze and trust services sanctions. Notably, Moscow Exchange, SPB Exchange and National Settlement Depository are amongst some of the new Russian entries. Earlier this week,…
The US and UK introduced new prohibitions last month related to Russian-origin aluminum, copper, and nickel produced on or after April 13, 2024. The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued two determinations imposing new restrictions on the importation of Russian-origin aluminum, copper, and nickel produced on or after to April 13, 2024 (the “Covered Russian Metals”) into the United States, and on the provision by US persons or within…
The Office of Financial Sanctions Implementation (āOFSIā) published an update to the monetary penalties for breaches of financial sanctions guidance (āGuidanceā) on 2 May 2024 (seeĀ here).Ā The Guidance explains when and how OFSI will use its civil enforcement powers to impose monetary penalties for breaches of financial sanctions, including guidance on how such penalties will be calculated. The most recent changes primarily focus on Chapter 3 (Case assessment) of the Guidance. Following the recent update, OFSI…