The UK’s Office of Financial Sanctions Implementation (“OFSI”) has published updated guidance (the “Russia Sanctions Guidance”) on the implementation of the Russia (Sanctions) (EU Exit) Regulations 2019 (“UK Russia Regulations”), including a new FAQ addressing circumstances where a UK financial institution receives funds indirectly from or via a designated bank. In parallel with this update to its Russia Sanctions Guidance, OFSI has also published a new General Licence relating to Correspondent Banking Payments (INT/2023/3566356). Updated…
The UK, France and Germany (the European signatories to the Joint Collective Plan of Action (“JCPOA”) nuclear deal with Iran in 2015, referred to as the “E3”) have decided to retain certain sanctions previously imposed upon Iran. The press release published by the E3 announcing this decision is available here. The JCPOA was agreed in 2015 between the E3/EU+3 (China, France, Germany, the Russian Federation, the United Kingdom and the United States, with the EU’s…
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,…