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,…
In recent weeks, there have been a number of noteworthy developments highlighting the increasing focus that US, EU, UK and other governments are placing on the potential circumvention of sanctions against Russia, and the roles of third countries and companies in facilitating the circumvention or undermining of such sanctions measures. These anti-circumvention efforts are taking place in the context of the G7’s concerted effort to bolster sanctions enforcement around the world, through the creation of…
On 22 February 2023, Dutch Customs published a press release on its website indicating that the additional EU sanctions measures against Russia and Belarus will enter into force on 24 February 2023. Although relevant legislative texts have not yet been published, the release suggests that the “tenth package” of EU sanctions against Russia will include: an extension of the export restrictions related to dual-use goods and goods which could contribute to the enhancement of Russian…
I. Adoption of fifth EU Sanctions Package On 13 April, in light of Russia’s ongoing military aggression against Ukraine, the Swiss Federal Council decided to fully adopt the new sanctions introduced by the EU in its fifth sanctions package against Russia on 8 April (see blog post here). The Ordinance on Measures connected with the Situation in Ukraine (the “Ordinance”) will now be revised accordingly. It will be published and enter into force some time…