October 2023 marked the first anniversary of the enhanced partnership between the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the United Kingdom Office of Financial Sanctions...more
On 24 February 2023, the U.S. intensified its sanctions on Russia and released new trade control measures targeting key sectors, evasion efforts, and military supplies. Taken together, the additional sanctions, export...more
From 15 June 2022 the Economic Crime (Transparency and Enforcement) Act 2022 will introduce changes to the enforcement of UK sanctions laws that parallel enforcement powers held by the Office of Foreign Assets Control...more
Today the UK government has adopted the “first barrage of UK economic sanctions against Russia” as UK Prime Minister Boris Johnson warned that Russian President Vladimir Putin is “bent on a full scale invasion of Ukraine”. UK...more
2/23/2022
/ Economic Sanctions ,
EU ,
Executive Orders ,
Exports ,
Financial Institutions ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
UK ,
Ukraine
The Court of Justice of the EU has interpreted for the first time the Blocking Regulation. The ruling confirms that it is possible to terminate contracts with a US designated person without providing reasons. However, in...more
As of 16 March 2020 Iran Air and a number of other entities were placed on the Bureau of Industry and Security's (BIS) Entity List.
Summary -
Companies that use Iran Air as transport, particularly companies engaging in...more
3/17/2020
/ Airlines ,
Aviation Industry ,
Bureau of Industry and Security (BIS) ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Policy ,
General Licenses ,
Iran ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Prohibited Transactions
On 6 November we held a breakfast seminar focusing on the most important sanctions issues affecting the City and how to manage compliance with different financial sanctions regimes effectively.
...more
12/3/2019
/ Anti-Money Laundering ,
Asset Management ,
Cooperative Compliance Regime ,
Corruption ,
Data Management ,
Economic Sanctions ,
EU ,
Financial Institutions ,
General Data Protection Regulation (GDPR) ,
Know Your Customers ,
Office of Foreign Assets Control (OFAC) ,
Personal Data ,
Private Equity ,
Regulatory Requirements ,
Sanction Violations ,
UK ,
White Collar Crimes
On 14 October, President Donald Trump issued Executive Order 13894, Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Syria (EO).
...more
10/18/2019
/ Blocked Person ,
Economic Sanctions ,
Executive Orders ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Syria ,
Trump Administration ,
Turkey ,
Unauthorized Transactions
On 5 August 2019 the Trump administration issued Executive Order 13884 (the executive order) imposing sweeping sanctions against the government of Venezuela, including its agencies and instrumentalities as well as any...more
On 2 May 2019, the U.S. Treasury's Office of Foreign Assets Control ("OFAC"), the agency responsible for enforcing economic sanctions, published "A Framework for OFAC Compliance Commitments" (the "Framework") which outlines...more
7/3/2019
/ Cooperative Compliance Regime ,
Economic Sanctions ,
Failure to Comply ,
Foreign Policy ,
Foreign Relations ,
Framework Agreement ,
Fund Managers ,
Internal Controls ,
Investment Funds ,
Investment Management ,
Office of Foreign Assets Control (OFAC) ,
Private Equity ,
Risk Assessment ,
Sanction Violations
On 2 May 2019 the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued "A Framework for OFAC Compliance Commitments" (the framework), which outlines five components OFAC considers to be essential...more