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
3/27/2025
/ Compliance ,
Due Diligence ,
Economic Sanctions ,
Enforcement Actions ,
Office of Financial Sanctions Implementation (OFSI) ,
Penalties ,
Regulatory Requirements ,
Reporting Requirements ,
Risk Management ,
Russia ,
UK
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
3/17/2025
/ Asset Freeze ,
Economic Sanctions ,
EU ,
Foreign Policy ,
Foreign Relations ,
International Trade ,
National Security ,
NATO ,
Russia ,
UK ,
Ukraine ,
United States
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
Key Takeaways - On 12 September 2024, the UK government published the Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 (the “Regulations”), which will come into force on 10 October 2024. The...more
Key Takeaways - On 3 July 2024, the Council of the European Union (the “EU Council”) published its revised Update of the EU Best Practices for the effective implementation of restrictive measures (“Best Practices”).This...more
7/23/2024
/ Best Practices ,
Buyback Programs ,
Economic Sanctions ,
EU ,
Limited Liability Company (LLC) ,
Majority Shareholders ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Shell Corporations ,
Trusts ,
UK
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
12/27/2023
/ Asset Freeze ,
Banking Sector ,
Cryptocurrency ,
Economic Sanctions ,
EU ,
European Economic Area (EEA) ,
Export Controls ,
Fund Transfers ,
G7 ,
Imports ,
Information Sharing ,
Insurance Industry ,
Licensing Rights ,
Metals ,
Oil Prices ,
Pipelines ,
Propane ,
Reporting Requirements ,
Russia ,
SDN List ,
Software ,
Technology Sector ,
Telecommunications ,
Trade Restrictions ,
Transparency ,
UK
Key Takeaways -
On 17 November 2023, the Foreign, Commonwealth & Development Office (FCDO) and Office of Financial Sanctions Implementation (OFSI) published new guidance on Ownership and Control: Public Officials and...more