Poland is an EU member state that follows a dual sanctions regime. This member state enforces EU sanctions, in addition to enforcing national sanctions that go beyond them. Businesses holding the status of an “obliged entity” under Polish AML legislation must take into account a new list of financial sanctions released on 26 September 2023. Universally applicable sanctions With respect to sanctions that must be complied with by all persons subject to the Polish jurisdiction,…
Following reports in August (see blog post here), on 6 September, the UK government formally announced the proscription of the Wagner Group. Parliament has passed an order, presented by the Home Secretary, to proscribe the Wagner Group under the Terrorism Act 2000. On 15 September, the order came into force, making it a criminal offence to belong to, encourage support for, assist or use the logo of the Wagner Group. Furthermore, the Wagner Group’s assets…
On August 14, 2023, the US State Department, the Labor Department, and the Commerce Department issued a business advisory (“Business Advisory”) highlighting key risks for companies operating in South Sudan. While it does not impose new legal obligations on companies, the Business Advisory highlights the fact that list-based sanctions remain in force targeting certain South Sudanese persons including designations under the US Treasury Department’s Office of Foreign Assets Control’s Specially Designated Nationals and Blocked Persons List, and…
On 11 August 2023, the UK Department for Business and Trade issued the Legal Advisory Services General Trade Licence (the “General Licence”) which came into force immediately. The General Licence was issued following the amendments to the Russia (Sanctions) (EU Exit) Regulations 2019 (the “UK Russia Regulations”) earlier in June (the “Amending Regulation”) which introduced certain restrictions to the provision of legal advisory services concerning sanctions against Russia. As summarised in our previous blog on…