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Key Compliance Tips on How to Respond to Information Requests From OFSI

On 8 May 2025, the United Kingdom’s Office of Financial Sanctions Implementation (OFSI) of HM Treasury published a penalty notice regarding a breach of financial sanctions by a UK registered company—Svarog Shipping & Trading...more

European Union Adopts 16th Package of Sanctions Against Russia

In a bid to further increase the pressure on Russia, the Council of the European Union has adopted additional measures which have been introduced in its 16th sanctions package. The new measures amending the framework Council...more

The Serious Fraud Office's Guidance on How to Best Avoid Prosecution

The United Kingdom’s Serious Fraud Office (SFO) recently published updated guidance on how corporates can best avoid or reduce the risk of prosecution in cases involving economic crimes such as bribery, fraud and corruption...more

The Latest OFSI Property and Related Services Threat Assessment

The United Kingdom’s Office of Financial Sanctions Implementation (OFSI) has published a report detailing suspected breaches of UK financial sanctions involving UK property and related services firms since February 2022 and...more

What Legal Services Providers Need to Learn From OFSI's Legal Services Threat Assessment

In its first-ever threat assessment of the UK legal sector, the UK’s Office of Financial Sanctions Implementation (OFSI) has raised red flags with regards to suspected sanctions breaches involving UK legal services providers...more

Europe: UK’s FCA Axes Proposed “Name and Shame” and D&I Requirements, and Delays Non-financial Misconduct Rules

The UK’s Financial Conduct Authority had proposed a so-called “name and shame” approach that would have allowed it, subject to certain safeguards, to disclose its investigations into firms publicly at an early stage (see our...more

FCA Backpedals: "Name and Shame" and Diversity and Inclusion Requirements Axed, and Non-financial Misconduct Rules Delayed

The United Kingdom’s Financial Conduct Authority (FCA) has announced significant changes to its regulatory approach, including dropping the obligation to “name and shame” firms under investigation, dropping the proposed...more

New Office of Financial Sanctions Implementation Financial Services Threat Assessment

On 13 February 2025, the Office of Financial Sanctions Implementation (OFSI) published its assessment of suspected sanctions breaches involving financial services firms since February 2022 (the Assessment). The Assessment...more

European Union Adopts 16th Package of Sanctions Against Russia, Further Impacting the Aviation Industry

On 24 February 2025, the European Union adopted the 16th Russia sanctions package. The new measures amending the framework Council Regulation (EU) 833/2014 are found and included in Council Regulation (EU) 2025/395. They...more

EU Sanctions—Article 8a “Best Efforts” Explained

On 24 June 2024, the European Union (EU) implemented its 14th package of sanctions against Russia to combat its continued aggression against Ukraine. A notable addition was made to Article 8a of Council Regulation (EU) No...more

Europe: Are the UK FCA’s Revised “Name and Shame” Proposals an Improvement?

In November 2024, the UK FCA released a Consultation which seeks to clarify its proposed approach to publicising ongoing enforcement action—dubbed the “name and shame” plan—and to assure the wider market of the plan’s...more

The FCA's Part 2 of Its "Name and Shame" Proposals: What You Need to Know

On 27 February 2024, the Financial Conduct Authority (FCA) published its Consultation Paper CP24/2, which revealed the FCA’s new intended approach to publicised enforcement action. This was quickly dubbed the “name and shame”...more

Article 8a "Best Efforts" Explained

On 24 June 2024, the European Union (EU) implemented its 14th package of sanctions against Russia to combat its continued aggression against Ukraine. The package introduced new anti-circumvention measures to strengthen...more

Guidance to Organisations on the Offence of Failure to Prevent Fraud

On 6 November 2024, the government released its much-anticipated guidance on the offence of failure to prevent fraud (the Guidance), as introduced by the Economic Crime and Corporate Transparency Act 2023 (the Act)....more

Sweeping Changes to Company Registration in the United Kingdom to Increase Transparency of Companies and the Integrity of the...

Background - The Economic Crime and Corporate Transparency Act (2023) (the Act) introduces the most significant changes to Companies House since corporate registrations were established in 1844. It is a new UK law that aims...more

Lessons on Effective Financial Crime Controls: The Starling Bank Example

The Financial Conduct Authority (FCA) recently levied a jaw-dropping £29 million fine against Starling Bank (Starling). The fine follows an investigation by the regulator, which exposed the bank's "shockingly lax" sanctions...more

Top Tips for Sanctions Compliance and Preventing Sanctions Evasion

On 24 September 2024, the G7 released updated guidance on the prevention of evasion of export controls and sanctions imposed on Russia. The aim of the guidance is to “assist industry in identifying Russian evasion practices...more

UK Office of Trade Sanctions Implementation New Enforcement Powers and Increased Reporting Obligations

On 12 September 2024, the UK government released the new Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 (the Regulations), which will come into force on 10 October 2024. The Regulations grant the...more

EU and UK Sanctions Briefing: The Luxury Goods Sector

The Impact of the EU and UK Russian Sanctions Regime on the Luxury Goods Sector - As the EU and UK Russian sanctions regimes continue to evolve, export controls are now affecting industries previously not often subject to...more

European Union Adopts New Sanctions Against Russia and Belarus

The European Union has again amended its sanctions against Russia and Belarus by adopting further legal acts, which put additional compliance obligations on EU companies. In particular, businesses will now have to undertake...more

How the Serious Fraud Office's Ambitious Five-Year Strategy Will Impact Businesses

The Serious Fraud Office (SFO) recently published its new five-year strategy for 2024-2029 (the Strategy), setting out its ambitious aspirations to become a “pre-eminent specialist, innovative and collaborative agency which...more

The Year Ahead: The Financial Conduct Authority's Ambitious Enforcement Plans for 2024/2025

In 2022, for the first time, the Financial Conduct Authority (FCA) published a three-year strategy setting out three key themes for promoting positive change, namely: (1) reducing and preventing serious financial harm and...more

UK and EU Sanctions Update–April 2024

The following alert provides an update on recent sanctions developments, including: The publication of the UK government’s first sanctions strategy. The announcement of over 50 new sanctions. Measures to strengthen the Oil...more

New Government Guidance and UK High Court Seeks to Settle Disarray in UK Sanctions Law

In October, the Court of Appeal suggested all companies operating in Russia could be considered to be sanctioned under UK law because they are potentially controlled by President Putin. This caused understandable alarm to...more

Why Corporates Are Now More Likely to Face Criminal Prosecution for the Actions of Their Employees

Significant Expansion to Corporate Criminal Liability Becomes Law in the United Kingdom - On 26 October 2023, the Economic Crime and Corporate Transparency Act (the Act) became law. Under the Act, corporations will become...more

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