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OFSI Imposes Monetary Penalty Against Former Moscow Office of International Law Firm for Sanctions Breaches

On March 20, 2025, the U.K.’s Office of Financial Sanctions Implementation (OFSI) announced that, in accordance with section 146 of the Policing and Crime Act 2017 (PACA), a monetary penalty of £465,000 had been imposed...more

EU/UK Russia Sanctions: Potential De-escalation of Sanctions and Divergence from U.S. Regime

Background - The war in Ukraine has taken a new diplomatic turn in recent weeks. Having historically aligned with the European Union (EU) and United Kingdom (UK) on its condemnation of Russia’s war in Ukraine, and the need...more

Extraterritorial Application of EU Sanctions Targeting Russia?

On 22 November 2024, the European Commission (the “Commission”) issued new frequently asked questions (FAQs) regarding the interpretation of the “Best Efforts” obligation in Article 8a of Council Regulation (EU) No. 833/2014...more

New EU & UK Sanctions

EU’s 12th Sanctions Package - On 19 December 2023, the Council of the European Union (EU) together with the Commission published its 12th round of sanctions....more

Reflections on Restructurings: UK Sanctions Regulator Clears Path for Future Restructurings

On 28 March 2023, the UK Office of Financial Sanctions Implementation of HM Treasury (“OFSI”) issued the “Bond amendments and restructurings for non-Designated Persons” general licence (General Licence - INT/2023/2824812)...more

Reflections on Restructurings: Impacts and Experiences of Unprecedented Sanctions Regimes

Since Russia’s invasion of Ukraine in February 2022, we have seen an extraordinary range of sanctions and export controls restrictions introduced by tens of countries worldwide. The current sanctions imposed on Russia by the...more

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