In a recent decision, the English High Court has demonstrated its willingness to interpret contractual provisions broadly so as to enable performance in circumstances where the imposition of sanctions on a counterparty...more
As Russia’s war in Ukraine passes the one-year mark, and the battles on the ground move forward with escalating levels of ferocity, governments around the world continue to coordinate and respond with increasingly severe...more
3/3/2023
/ Asset Freeze ,
Bureau of Industry and Security (BIS) ,
Central Bank of Russia ,
Economic Sanctions ,
EU ,
Export Controls ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
UK ,
Ukraine
As Russia’s war in Ukraine stretches into its tenth month, governments around the world continue to coordinate and respond with increasingly severe sanctions and export controls....more
12/7/2022
/ Crude Oil ,
Economic Sanctions ,
EU ,
Export Controls ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Oil Prices ,
Reporting Requirements ,
Russia ,
UK ,
Ukraine
On 25 April 2022, in collaboration with the UK Independent Anti-Slavery Commissioner, the Financial Reporting Council (“FRC”) published a report on Modern Slavery Reporting Practices in the UK (the “Report”). ...more
As Russia’s bloody invasion of Ukraine nears the end of its second month, with regular reports of human rights violations, possible chemical weapons attacks, and head of state musings regarding whether this campaign amounts...more
4/18/2022
/ Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
EU ,
Export Controls ,
Financial Markets ,
Foreign Relations ,
Japan ,
Most-Favored Nations ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
Trade Relations ,
UK ,
Ukraine
As Russia’s brutal invasion of Ukraine stretches on into its second month, the United States, European Union, United Kingdom, and other global allies have continued to pour additional funding and arms into Ukraine while...more
3/23/2022
/ Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
EU ,
Export Controls ,
Funding ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SWIFT ,
UK ,
Ukraine ,
US Department of State
After less than a week of a full-scale war between Russia and Ukraine, the post-Cold War global architecture appears irrevocably shattered, as Western nations line up to offer support and military and economic aid to Ukraine...more
3/1/2022
/ Airspace ,
Asset Freeze ,
Economic Sanctions ,
EU ,
Export Administration Regulations (EAR) ,
Export Controls ,
G7 ,
Popular ,
Russia ,
SWIFT ,
UK ,
Ukraine ,
United States
The UK government has widened the scope of its Russia sanctions regulations in anticipation of a Russian invasion of Ukraine. The amendments to the existing Russia sanctions regulations significantly broaden the definition of...more
On 14 October 2021, the Office of Financial Sanctions Implementation (“OFSI”) published its annual review for the financial year 2020-2021 (the “Annual Review”). Under the leadership of its new Director, Giles Thomson,...more
During the course of the last three months, there has been a significant focus on the activity of the Serious Fraud Office (SFO). The SFO has achieved its objectives in some instances; see, for example, our article below...more
On 29 April 2021, the Financial Services Bill received Royal Assent in the UK, becoming law as the Financial Services Act 2021 (the “Act”). This is the first significant step for the UK in shaping its financial services...more
In our Quarterly Review, we bring you important UK developments relating to business crime, investigations, and regulatory enforcement from the last three months.
As the UK gets used to life outside the EU and implements...more
3/29/2021
/ Asset Freeze ,
Civil Monetary Penalty ,
Corporate Crimes ,
Corruption ,
Criminal Justice Act ,
EU ,
Financial Conduct Authority (FCA) ,
Foreign Corporations ,
HMRC ,
Human Rights ,
Money Laundering ,
NCAs ,
Popular ,
Sanctions ,
Serious Fraud Office (SFO) ,
Travel Ban ,
UK ,
UK Brexit ,
Unexplained Wealth Orders (UWOs)
Addressing the responsibility and accountability of companies in relation to their environmental and human rights impact has long been at the top of the agenda at the European level. On 10 March 2021, the European Parliament...more
Nearly one year after its introduction to the House of Commons, the Medicines and Medical Devices Bill 2019‑2021 (the Bill) was granted Royal Assent on 11 February 2021, becoming law as the Medicines and Medical Devices Act...more
2/25/2021
/ Clinical Trials ,
Criminal Sanctions ,
EU ,
Life Sciences ,
Medical Devices ,
Medical Technology Companies ,
Medicines and Healthcare Products Regulatory Agency (MHRA) ,
Pharmaceutical Industry ,
Trade Agreements ,
UK ,
UK Brexit ,
UK Parliament
As Brexit is finally completed in the UK, from 1 January 2021, the Medicines and Healthcare products Regulatory Agency (“MHRA”) will be the UK’s standalone medicines and medical devices regulator. Transition from the EU...more
The Court of Appeal, in Lamesa Investments Ltd v Cynergy Bank Ltd [2020] EWCA Civ 281, has found that a party in an English law governed “Tier 2 Capital” subordinated facility agreement with contractual language addressing...more
In our Quarterly Review, we bring you important UK developments relating to Business Crime, Investigations and Regulatory Enforcement from the last three months. Please contact us if you would like to discuss any of these...more
6/23/2020
/ Bring Your Own Device (BYOD) ,
Coronavirus/COVID-19 ,
Corporate Crimes ,
Cybersecurity ,
EU ,
Financial Conduct Authority (FCA) ,
NCAs ,
NCSC ,
Office of Financial Sanctions Implementation (OFSI) ,
Popular ,
Serious Fraud Office (SFO) ,
UK ,
Unexplained Wealth Orders (UWOs)