On 29 May 2023, Poland imposed sanctions on 365 citizens of Belarus, as well as other individuals and entities. Polish law requires an individual decision and scope of sanctions to be determined with respect to each designated person, however the measures typically include: freezing of funds and economic resources prohibition of making funds or economic resources available prohibition of knowing and voluntary participation in activities aiming at, or resulting in, circumvention of the above measures…
Following the inaugural post for the new Sanctions Enforcement Around the World blog series focused on enforcement trends in Australia, we now turn our attention to the sanctions enforcement trends in Ukraine. 1. What are recent sanctions enforcement trends in Ukraine? In response to the full-scale Russian military invasion of Ukraine in February 2022, Ukraine has significantly enhanced both its sanctions legislation and enforcement practice. To recap, the following are the key legislative developments aiming…
The Government of Canada recently introduced Part 1 of the budget implementation bill (Bill C-47), which completed its second reading before the House of Commons and has been referred to the Standing Committee on Finance. The Bill proposes novel amendments, including “deemed ownership” provisions (the “Deeming Provisions”) to the Special Economic Measures Act (“SEMA”) and the Justice for Victims of Corrupt Foreign Officials Act (the “Sanctions Laws”)[1] and it demonstrates that the Government intends to rely…
As discussed in our recent blog post (available here), the UK Office of Financial Sanctions Implementation (“OFSI”) has updated its guidance on enforcement and monetary penalties for breaches of financial sanctions (the “Monetary Penalties Guidance”, available here), to include a number of paragraphs setting out OFSI’s expectations around the nature and type of due diligence that companies should undertake when assessing whether an entity is owned or controlled by one or more designated persons, for sanctions…