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Economic Sanctions

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New EU rules criminalising the violation of EU sanctions enter into force

As from 19 May, the new rules will ensure that such violations can be criminally investigated and prosecuted in all Member States including violation and circumvention of EU sanctions, such as for example: failing to freeze assets; breaching travel bans and arms embargoes: providing prohibited or restricted economic and financial services, transferring funds that should be frozen to a third party…

US Treasury sanctions a cybercrime network associated with the 911 S5 Botnet

The 911 S5 botnet was a malicious service that compromised victim computers and allowed cybercriminals to proxy their internet connections through these compromised computers. Once a cybercriminal had disguised their digital tracks through the 911 S5 botnet, their cybercrimes appeared to trace back to the victim’s computer instead of their own…

OFSI announces the funds of non-designated third parties involving designated credit or financial institutions

Any act which would otherwise breach the prohibitions in Regulations 11 to 15, 17 and 17A of the Russia Regulations is exempt from those prohibitions to the extent required to give effect to the permissions in this licence.

European Council announces EU to set up new framework for restrictive measures against those responsible for human rights violations

Thew decision to introduce new regime is a part of EU response to the increasing systematic repression in Russia. The new system will allow the EU to those who provide technical or material support to people and communities who commit human rights abuses to people in Russia. The new sanctions regime will imposes trade restrictions on the export of technology…

OFSI releases General licence INT/2024/4761108 for funds of non-designated third parties involving designated credit or financial institutions (“Personal Remittances”)

OFSI reissued General Licence under Regulation 64 of The Russia (Sanctions) (EU Exit) Regulations 2019 which is subject to certain conditions which allows a person to make use of the retail banking services of a designated Credit or Financial Institution provided that the payments made or received are intended for the personal use of a person…

UK Govt publishes the Sanctions (EU Exit) (Miscellaneous Amendments and Revocations) Regulations 2024 (the “Regulations“), to make amendments to a number of UK sanctions regimes

The updates include: The Regulations introduce “director disqualification sanctions” into a number of UK regimes (Venezuela, Guinea-Bissau, Belarus, Zimbabwe, Chemical Weapons, Syria, Russia, Guinea, Cyber, Bosnia & Herzegovina, Nicaragua, Global Human Rights, Unauthorised drilling activities in the Eastern Mediterranean, Global Anti-Corruption, and Myanmar)…

US Treasury designates sanctions evaders facilitating illicit arms transfers between the DPRK and Russia

Targets two Russian individuals and three Russia-based entities for facilitating weapons transfers between Russia and the Democratic People’s Republic of Korea (DPRK).

UK House of Lords and House of Commons debates the efficacy and circumvention of sanctions on Russia

The key points include: the UK Foreign Secretary Lord Cameron will raise the issue of the “shadow fleet” and circumvention of the oil price cap at the European Political Community meeting in July 2024; the G7’s “lead idea” re seizure of Russian assets is transferring the windfall interest on Russian state assets to Ukraine, but the UK will not rule out looking at using the underlying assets themselves in the future; and the first OFSI financial penalties are expected this year.



UK Govt publishes guidance to support businesses in their Russia sanctions compliance procedures for the sale and brokering of oil tankers to third countries

The UK government is issuing this guidance for those involved in the sale and brokering of second-hand vessels to third countries. It provides further information and tools to counter current and emerging trends related to Russian sanctions evasion…

OFAC extends permission to transact with certain energy-related entities based in Russia

OFAC issued General License 8I pursuant to Russian Harmful Foreign Activities Sanctions Regulations (“RuHSR”), 31 CFR part 587. General License 8I was issued to extend the authorization of energy-related transactions to November 1, 2024 for transactions that involve one or more of the entities: State Corporation Bank for Development and Foreign Economic Affairs Vnesheconomank…

UK Govt hosts a senior US government delegation for the second US-UK Strategic sanctions dialogue

The  US and UK reaffirmed that sanctions and export controls are essential tools of national security policy. The delegations discussed the uses of targeted, coordinated sanctions and export control measures to deter and disrupt malign activity and to defend international norms…

FinCEN issues advisory on Iran-backed terrorist organisations, providing red flags that may assist FIs in identifying related suspicious activity

The Advisory highlights the means by which certain terrorist organizations receive support from Iran and describes several typologies these terrorist organizations use to illicitly access or circumvent the international financial system to raise, move, and spend funds…