Category

UK Related Items and Policy

Category

What are the main changes: For breaches of financial sanctions that are committed after 15 June 2022, OFSI will be able to impose civil monetary penalties on a strict civil liability basis. This means that going forward OFSI will not have to prove that a person had knowledge or reasonable cause to suspect that they were in breach of financial sanctions. OFSI will continue to have the burden of proving that the financial sanctions breach…

On 26 February 2021, the European Commission, France, Germany, Italy, the UK, Canada and the US released a coordinated statement condemning the Russian invasion of Ukraine and committing to further restrictive measures, including: Ensuring that selected Russian banks are removed from the SWIFT messaging system, which facilitates global cross-border financial transfers. The affected banks have not yet been named.Imposing restrictive measures that will prevent the Russian Central Bank from deploying its international reserves in ways…

The Office of Financial Sanctions Implementation (“OFSI”) published an update to the monetary penalties for breaches of financial sanctions guidance on 28 January 2022 (see here). The guidance sets out how OFSI will decide when to use its civil enforcement powers to impose monetary penalties for breaches of financial sanctions, and how such penalties will be calculated. In the recent update, changes were made to the guidance on when OFSI will consider investigation and enforcement…

On Thursday 6 January 2022, the European Commission published Delegated Regulation (EU) 2022/1, updating the list of dual-use items contained in Annex I to Regulation (EU) 2021/821 (the “EU Dual Use List”). Regulation (EU) 2021/821, which was published in June last year and came into effect on 9 September last year, introduced key changes to modernise the EU export controls regime for dual use items. Please see our previous post for an overview of changes,…