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OFSI Issues First-Ever Monetary Penalty for a Failure To Provide Information: Key Considerations for Companies

The Offence and Penalty - On 8 May 2025, the UK’s Office of Financial Sanctions Implementation (OFSI) published its 11 April 2025 notice of its first-ever monetary penalty for an information offence relating to financial...more

UK Sanctions Update: Further Sanctions Against Russia Introduced, More Syria Sanctions Lifted and First UK Prosecution for a...

The UK’s sanctions regimes remain dynamic as they continue to respond to geopolitical changes. In recent weeks, the UK has enhanced its Russia sanctions, despite the uncertain direction of the international sanctions on...more

The UK Foreign Influence Registration Scheme – What You Need to Know

On 1 April 2025, the UK government confirmed that the Foreign Influence Registration Scheme (FIRS) — which was established under the National Security Act 2023 — will come into force from 1 July 2025. The UK government has...more

UK Crime and Policing Bill: New Measures To Facilitate Prosecution of Companies and High-Net-Worth Individuals

Key Points - If the Crime and Policing Bill (CPB) is enacted in current form, it will make it significantly easier for companies to be held liable for criminal offences committed by their senior managers. Coupled with the...more

An Ounce of Prevention Podcast | Preparing for the UK Failure to Prevent Fraud Offence [Video]

We are pleased to present the premiere episode of “An Ounce of Prevention,” a podcast focused on compliance and white collar crime trends. Our first episode — hosted by London white collar defense and investigations partner...more

UK, France and Switzerland Focus on Enforcement With New Anti-Corruption Taskforce

On 20 March 2025, enforcement authorities in the UK, France and Switzerland announced the creation of the International Anti-Corruption Prosecutorial Taskforce. The taskforce is comprised of: - The UK’s Serious Fraud...more

Latest EU Sanctions Extend Asset Freezes, Restrict Oil Industry Dealings and Target ‘Shadow Fleet’

The European Union (EU) has reaffirmed its sanctions policy toward Russia by implementing two rounds of restrictive measures that are intended to further intensify pressure on Russia’s government and economy. Specifically,...more

Khouri: Is UK-US Extradition on Its Way to Becoming an Ex-Tradition?

On 12 February 2025, the UK Supreme Court handed down its decision in El-Khouri v Government of the United States of America (El-Khouri), declining to extradite Joseph El-Khouri to the US. The ruling marks a pivotal moment in...more

UK Sanctions: A New Package, Guidance and Legal Clarifications

The future of international sanctions on Russia is not settled. Whilst the representatives of the US and Russia met in Saudi Arabia on 18 February 2025 to discuss possible avenues to peace in Ukraine, the foreign ministers of...more

Crypto-assets: Opportunities in the New Regulatory Climate

On 5 February 2025, Skadden hosted a series of panel discussions looking at the evolving EU, UK and US crypto-asset landscape... The discussion explored how market participants and investors can best anticipate and prepare...more

Political Changes Are Unlikely To Fundamentally Alter Key Sanctions

Key Points - - Political transitions in the West notwithstanding, we expect economic sanctions to remain a key response to geopolitical issues. - Current sanctions policy priorities are unlikely to shift markedly in...more

Europe Moves Toward Further Regulation of Forced Labour in Supply Chains

A number of jurisdictions globally are enhancing their supply chain-related regulations. The European Union’s latest regulation in this respect, the EU Forced Labour Regulation (FLR), was adopted on 19 November 2024. The FLR...more

UK Government Publishes Guidance on the New ‘Failure to Prevent Fraud’ Offence

On 6 November 2024, the UK government published its guidance on the new ‘failure to prevent fraud’ offence, which was introduced in the Economic Crime and Corporate Transparency Act 2023 (ECCTA 2023).1 We covered the details...more

The Sanctions Puzzle: Key Areas To Watch in 2025 and Beyond

The past weeks and months have brought about tremendous political change in the West, as we move toward a new U.S. administration, a new College of Commissioners in Brussels and a new Polish presidency of the Council of the...more

Fintech Focus Podcast | Sanctions Compliance: Regulators Set Their Sights on Fintechs [Video]

As regulators such as the UK’s Financial Conduct Authority have turned their attention to fintechs, sanctions compliance will remain a priority for the sector. Joseph Kamyar is joined by white collar defense and...more

Sanctions Compliance: Regulators Set Their Sights on Fintechs [Video]

As regulators such as the UK’s Financial Conduct Authority have turned their attention to fintechs, sanctions compliance will remain a priority for the sector. Joseph Kamyar is joined by white collar defense and...more

OFSI Issues First Monetary Penalty for Breach of Sanctions Imposed on Russia in Response to Its Invasion of Ukraine

On 27 September 2024, the UK’s financial sanctions regulator, the Office of Financial Sanctions Implementation (OFSI), announced that it had issued its first monetary penalty for a breach of UK financial sanctions imposed...more

UK Government Announces Powers of New Trade Sanctions Enforcement Agency

On 12 September 2024, the UK government published The Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 (Regulations) which, among other things, set out the powers of the new Office of Trade...more

UK Modern Slavery Act: The Future of Transparency in Supply Chains

When the UK Modern Slavery Act 2015 (Act) came into force, it was considered a landmark legal development globally. The UK was one of the first jurisdictions to introduce a legal requirement concerning transparency in supply...more

New ‘Failure To Prevent Fraud’ Offence Expected To Come Into Force in the UK Shortly

The UK government introduced a major overhaul of its framework for addressing financial crime — and brought into force numerous significant changes — when the Economic Crime and Corporate Transparency Act 2023 (the Act)...more

UK Secondary Sanctions? The UK Broadens Its Designation Criteria To Target Foreign Persons With Exposure to the Russian Government...

On 31 July 2024, the UK government broadened its Russian sanctions regime, giving the government express power to impose sanctions on persons who provide financial services, or make available funds, economic resources, goods...more

‘Control’ Under the UK’s Sanctions: The Emergence of Clarity?

Russia’s invasion of Ukraine has resulted in unprecedent judicial scrutiny of the UK’s sanctions regulations. While the judgments delivered in many cases have provided companies with needed certainty on some topics, the...more

Significant UK Court of Appeal Decision Confirms the Applicability of the UK’s Proceeds of Crime Legislation to Illegality in...

The UK Court of Appeal recently held that the National Crime Agency’s decision not to investigate whether cotton goods manufactured in China and imported to the UK were the product of forced labour was unlawful — a decision...more

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