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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

REPO for Ukrainians Act Provides for the ‘Repurposing’ of Seized Russian Sovereign Assets

On April 24, 2024, President Joe Biden signed into law a high-profile package of national security legislation (Public Law 118-50). While most press reports focused on the spending elements of the package (appropriating funds...more

UK Publishes First Sanctions Strategy and New Licensing Guidance

On 22 February 2024, shortly before the second anniversary of Russia’s invasion of Ukraine, the UK government published its first sanctions strategy (the Strategy). The Strategy explains the UK’s use and implementation of...more

UK Announces Creation of New Trade Sanctions Enforcement Agency and Introduces Further Sanctions Against Russia

With Russia’s invasion of Ukraine nearing the end of its second year, the United Kingdom has continued to introduce sanctions measures against Russia, with the latest round announced on 14 December 2023....more

US Authorities Hammer Home the Importance of Self-Disclosing Sanctions and Export Control Violations

On July 26, 2023, the U.S. Department of Justice’s (DOJ’s) National Security Division (NSD), the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), and the U.S. Department of the Treasury’s Office of Foreign...more

DOJ Doubles Down on Efforts To Incentivize Early Self-Reporting and Cooperation

On January 17, 2023, the U.S. Department of Justice (DOJ) announced revisions to the Criminal Division’s Corporate Enforcement Policy. The revisions follow Deputy Attorney General (DAG) Lisa Monaco’s September 2022...more

US, UK and EU Expand and Amend Russian Sanctions, Responding to Purported Annexations of Ukrainian Regions

In light of the recent referendums and purported annexation by Russia of four territories of Ukraine on September 30, 2022, the United States, United Kingdom and European Union have expanded measures and provided additional...more

US, UK and EU Impose New Sanctions and Export Controls on Key Elements of Russian Economy

Since the publication of our March 24, 2022, and March 17, 2022, client alerts, the U.S., U.K. and European Union, among other allied nations, have imposed additional sanctions and export controls on key elements of the...more

UK and EU Impose Further Ukraine-Related Sanctions on Russia and Belarus

Since the publication of our 9 March 2022 client alert, the US, UK and EU and other allied nations have imposed additional sanctions and export controls on key elements of the Russian economy. This client alert summarizes the...more

US, UK and EU Ramp Up Sanctions and Export Controls as Russia’s Invasion of Ukraine Continues

Since the publication of our February 26, 2022, client alert, the United States, United Kingdom and the European Union, among other allied nations, have imposed additional sanctions and export controls on key elements of the...more

US, UK and EU Impose Significant Sanctions and Export Controls in Response to Russia’s Invasion of Ukraine

The United States, United Kingdom and the European Union, among other allies, have moved swiftly in response to the Russian Federation’s invasion of Ukraine. Merely hours after Russia’s announcement on February 21, 2022, that...more

Navigating the Future Landscape of the EU Blocking Statute

The European Union Blocking Statute was originally adopted in 1996 to counteract US sanctions on Cuba, Iran and Libya, but following a memorandum of understanding entered into between the EU and the US, it has seldom been...more

UK Steps Up Enforcement Efforts With New Global Anti-Corruption Sanctions Regime

On 27 April 2021, the UK implemented its new Global Anti-Corruption Sanctions Regime, enhancing its existing Global Human Rights Sanctions Regime, which came into force in July 2020. The new Global Anti-Corruption Sanctions...more

Impact of Brexit on UK and EU Sanctions Frameworks

The U.K. adopted an autonomous financial sanctions regime when it exited the European Union on December 31, 2020. The U.K. and EU have both stated that they intend to coordinate post-Brexit sanctions policy as much as...more

Impact of COVID-19 on White Collar Enforcement

While enforcement agencies have yet to indicate that they intend to put their pens down in response to COVID-19, there is anecdotal evidence that some agencies have slowed their investigations as remote working impacts matter...more

Cross-Border Investigations Update - September 2019

This issue of Skadden’s semiannual Cross-Border Investigations Update takes a close look at recent cases, regulatory activity and other key developments, including a review of the first year of GDPR enforcement, analysis of...more

"UK Tracks OFAC Model in Issuing Guidance on Monetary Penalties for Breaches of Financial Sanctions"

As previously reported, the Policing and Crime Act 2017 (the Act) introduced a series of major changes to the U.K. financial sanctions regime. The changes, which came into force on April 1, 2017, included the creation of new...more

The FCPA Lives On

On Tuesday, April 18, 2017, Acting Principal Deputy Assistant Attorney General Trevor McFadden (the P-DAAG) spoke at the 10th Anti-Corruption, Export Controls & Sanctions Compliance Summit in Washington, D.C. After much...more

"UK Establishes New HM Treasury Office to Implement Financial Sanctions"

On March 31, 2016, the U.K. launched the new Office of Financial Sanctions Implementation (OFSI) within HM Treasury. OFSI, which assumes the financial sanctions responsibilities previously carried out by HM Treasury’s Asset...more

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