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…
In keeping with tradition, we are pleased to invite you to our annual Global Year-End Review of Import/Export & Trade Compliance Developments Conference to be held between December 4-7. The conference will provide valuable insights on the latest developments, challenges and opportunities in the ever-changing landscape of international trade.We will kick off the conference with an in-person networking session and panel discussion on December 4 on the pressing topic of “Navigating Trade Compliance Amidst Geopolitical Disruptions…
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…