The Office of Financial Sanctions Implementation (“OFSI“) published an update to the monetary penalties for breaches of financial sanctions guidance (“Guidance”) on 2 May 2024 (see here). 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…
On 4 March 2024, the UK Foreign, Commonwealth and Development Office (“FCDO”) published a Post-Legislative Scrutiny Memorandum (the “Memorandum”) for the UK Sanctions and Anti-Money Laundering Act 2018 (“SAMLA”). The Memorandum (available here) provides an assessment of the functioning of SAMLA and UK sanctions regimes underpinned by SAMLA, following the UK’s introduction of an autonomous sanctions framework post-Brexit. The Memorandum covers a broad range of areas relating to SAMLA and the UK’s sanctions framework, including…
On February 1, 2024, President Biden issued Executive Order 14115 (“EO 14115”) targeting persons involved in activities that threaten the peace, security, and stability in the West Bank. Meanwhile, the UK government announced on 12 February 2024 sanctions on “extremist Israeli settlers” who have committed human rights abuses against Palestinian communities. Pursuant to EO 14115, four individuals were added to the Specially Designated Nationals and Blocked Persons List (“SDN List”). Concurrently, the US Treasury Department’s…
The leader of Russia’s political opposition, Alexei Navalny, died in a Siberian prison on February 16, just over a week before the two-year anniversary of Russia’s full-scale invasion of Ukraine on February 24. Both Navalny’s death and the anniversary of the invasion were cited as the motivations behind the latest rounds of sanctions against Russia. Members of our global sanctions team in our offices in the US, UK, Sweden, Australia, and Canada summarize the latest…