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Losing control: What the Mints Court of Appeal judgment means for UK sanctions

On 6 October 2023, the Court of Appeal handed down judgment in the case of Mints & ors v PJSC National Bank Trust & anor [2023] EWCA 1332. The judgment confirmed that the UK’s sanctions do not preclude the English courts...more

UK sanctions systems and controls: lessons learnt

The UK Financial Conduct Authority (FCA) has assessed the systems and controls relating to sanctions compliance for over 90 firms across a range of sectors and summarised its findings of good and poor practice. Acknowledging...more

UK Russia sanctions: back in the spotlight

Sanctions and the systems and controls companies have in place to comply with them seem to be back in the spotlight. In addition to guidance recently published by the UK Financial Conduct Authority, a number of recent...more

New sanctions guidance on "ownership and control" and due diligence expectations

Updated guidance regarding the enforcement of financial sanctions from the UK’s Office of Financial Sanctions Implementation (OFSI) was published on 16 March 2023. The guidance, which sits alongside OFSI’s general guidance on...more

The UK updates its sanctions guidance on “ownership and control” and sets out its due diligence expectations

The UK’s Office of Financial Sanctions Implementation (OFSI) published updated guidance regarding the enforcement of financial sanctions on 16 March 2023. The guidance, which sits alongside OFSI’s general guidance on...more

UK sanctions against Russia: the pressure intensifies

The UK Government has introduced two further packages of sanctions against Russia in quick succession....more

UK sanctions – prohibitions on new investments and professional and business services

In the past week, the UK has further tightened its sanctions targeting Russia. The new sanctions include the introduction of new trade-related restrictions on a wide variety of goods (including gold, oil, coal and “G7...more

UK and EU sanctions enforcement – increasing focus

In the past weeks, the UK and EU regulatory authorities have made a series of announcements in relation to the enforcement of sanctions....more

Financial sanctions enforcement in the UK: upping the ante

In the past week, the UK Government has made a series of announcements in relation to the enforcement of financial sanctions in the UK....more

Mistaken breach of UK Financial Sanctions: possible exposure and what to do

The UK sanctions imposed as a result of Russia’s invasion of Ukraine have undoubtedly put intense pressure on businesses to review existing commercial arrangements and tighten sanctions compliance systems and controls. But...more

Sanctions-related reporting and compliance obligations for UK financial institutions

Financial institutions face a myriad of sanctions compliance issues arising out of the multiplicity of legal, regulatory and reporting regimes that they are subject to. For Financial institutions in the United Kingdom, the...more

A closer look: United Kingdom - The Sanctions and Anti-Money Laundering Act: The UK Sanctions and AML regimes after Brexit

When the Sanctions and Anti-Money Laundering Act 2018 was first proposed, the expectation was that it would enable the UK to maintain the status quo after it leaves the EU in the areas of sanctions and anti-money laundering...more

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