On 1 December, it was announced that the UK Office of Financial Sanctions Implementation (“OFSI”) and the UK Financial Conduct Authority (“FCA”) had entered into a memorandum of understanding (“MOU”) on 21 November 2023 which outlines the agencies’ agreement to co-operate and share information relating to suspected or actual sanctions breaches with each other. This MOU replaces a previous MOU that had been in place since April 2019. In summary, under the MOU it has…

The UK Industry and Economic Security Minister, Nusrat Ghani, has today announced the creation of a new government unit to “crack down” on companies evading sanctions; the Office of Trade Sanctions Implementation (OTSI). The OTSI will launch in early 2024 once the new legal requirements are in place and will operate alongside the existing work the government is doing to ensure UK trade sanctions are adhered to. The unit will be responsible for civil enforcement of…

The UK Office of Financial Sanctions Implementation (“OFSI”) and the Foreign, Commonwealth and Development Office (“FCDO”) have issued joint guidance (“Joint Guidance”) on the application of the UK’s “ownership and control” test under financial sanctions legislation in circumstances involving designation of public officials. The Joint Guidance follows a significant amount of debate in relation to these issues, following the Court of Appeal’s recent judgment in the case Mints v PJSC National Bank Trust [2023] EWCA…