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…
The UK has adopted The Russia (Sanctions) (EU Exit) (Amendment) Regulations 2023. See here for an explanatory memorandum accompanying this legislation. The new legislation introduced and expands on current trade sanctions and comes into force today, Friday 21 April 2023. The sanctions significantly expand the restrictions on import and acquisition of revenue generating goods which originate in, or are consigned from, Russia. In particular:• the existing list of goods prohibited for import into the UK…
The G7 announced the creation of a new Enforcement Coordination Mechanism “to bolster compliance and enforcement of our measures and deny Russia the benefit of G7 economies” on the one-year anniversary of Russia’s invasion of Ukraine. Having focused on the enforcement of sanctions by the United States, United Kingdom, the European Union, Germany, France, Italy, and Canada in the past weeks, we continue our overview with enforcement trends in Japan. 1. What are the recent sanctions enforcement trends in Japan? Japan…
Having focused on the enforcement of sanctions by the United States, United Kingdom, the European Union, Germany, and France in the past weeks, we continue our overview with the current enforcement practice of the Italian authorities and the changes to be expected following the newly announced G7 Enforcement Coordination Mechanism. What are the recent sanctions enforcement trends in Italy? While there is minimal public information available on Italian enforcement activity, it is clear to us…