On 22 August, it was reported that the UK Government is considering the proscription of the Wagner group as a terrorist organisation under the Terrorism Act 2000. The Wagner group is a collection of individuals and entities globally making up the ‘Wagner Network’, which is engaged in military, economic, political, and influencing operations. They are known for being a private military company. Proscribing Wagner as a terrorist organisation would put it in the same legal…
The UK’s Financial Conduct Authority (FCA) plays a key role in monitoring how UK-regulated financial institutions guard against financial crime risks, and how effectively they implement financial crime policies and procedures. In recent months, as the UK and other governments have placed increasing focus on preventing the circumvention of sanctions targeting Russia, the FCA has taken a number of steps to emphasise its focus on how financial institutions are complying with financial and trade sanctions,…
In December 2022, the United Nations Security Council (the ‘UNSC’) adopted a resolution which introduced a standardised humanitarian exemption across UN regimes according to which activities necessary for humanitarian assistance and other activities that support basic human needs are exempt from sanctions in the form of asset freezes imposed by the Security Council or by its Sanctions Committees. All UN sanctions regimes except the Afghanistan regulations will now include a standardised humanitarian exception to the…
On October 17, 2022, the UK HM Treasury’s Office of Financial Sanctions Implementation (“OFSI”) and the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued a joint statement (OFSI statement here, OFAC statement here) to reiterate the close working relationship between the two agencies, explaining the rationale behind increased OFSI-OFAC co-operation and how this will manifest in practice. The statement follows a technical exchange attended by OFAC and OFSI in London, which concluded on…