On 12 September, the UK Government announced new powers for the civil enforcement of trade sanctions pursuant to the Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024, the “Trade Enforcement Regulations”). From 10 October 2024, the Government will be able to impose penalties of up to GBP 1 million or 50% of the value of breaches of trade sanctions (whichever is greater) in relation to certain breaches of UK trade sanctions. The new powers…
On 11 June 2024, the UK Court of Appeal handed down its judgment in the case of Celestial Aviation Services Limited v UniCredit Bank GmbH (London Branch) [2024] EWCA Civ 628. In summary, the Court of Appeal determined that, in the context of payment obligations under standby letters of credit (“LCs”), sanctions measures relating to financing the supply of restricted items can apply retrospectively as well as prospectively, significantly widening the scope of application of…
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…