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Economic Sanctions
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Atlantic Council publishes Global Sanctions Dashboard
This edition answers the most controversial question about the blocked Russian state assets: to seize them or not to seize them? and proposes a solution that would transfer funds directly and quickly to Ukraine without triggering a host of legal obstacles in the US…
OFSI expands Russia-related prohibitions on trust services
OFSI issues a new general license to further restrict Russian efforts to access trust services in the UK. This action was taken in response to enforcement agency evidence suggesting that UK-based trust and company service providers have been offering trust services to…
OFSI updates its Enforcement and Monetary Penalty Guidance
The updated Guidance includes paragraphs setting out OFSI’s expectations around the nature and type of due diligence that companies should undertake when assessing whether an entity is owned or controlled by one or more designated persons, for sanctions purposes…
EP briefing on ‘EU sanctions on Russia: Overview, impact, challenges
The European Parliament has unequivocally condemned Russia’s unjustified aggression against Ukraine, and has since demanded broader and better-enforced sanctions, including a secondary sanctions mechanism, as well as the confiscation of Russian assets frozen by the EU…
Global Advisory on Russian Sanctions Evasion issued by the Multilateral REPO Task Force
The REPO Task Force’s collective efforts have resulted in the freezing of tens of billions of dollars and the freezing or seizure of high-value goods or property. However, some sanctioned Russian elites and their financial networks have managed to evade sanctions and…
US Treasury Fact Sheet summarising outcomes from the Russian sanctions regime
Over 80% of Russia’s banking sector by assets are under U.S. sanctions, including the top 10 Russian-owned banks. More than 1,000 foreign companies reportedly have ceased or curtailed their operations in Russia since the start of the war, stifling investment and industrial…
EU agrees 10th package of sanctions against Russia
The package contains new listings plus trade and financial sanctions, including further export bans worth more than €11 billion, depriving the Russian economy of critical tech and industrial goods. It also steps up enforcement and anti-circumvention measures, including a new…
Basel Working Paper sheds fresh light on the sanctions and confiscation debate
The paper examines whether states should be able to confiscate sanctioned assets* purely on the basis that they have been sanctioned? The justifiability and legality of mechanisms such as Canada’s is currently the subject of debate. Two key issues include whether the…
US and UK sanction members of Russia-Based Trickbot Cybercrime Gang
The US and UK have imposed sanctions against seven leading members of a notorious Russian hacking gang known as Trickbot which is a malicious software at one point was counted among one of the internet’s most pernicious security threats, capable of stealing financial data…
FinCEN alert on potential U.S. real estate investments by sanctioned Russian elites, oligarchs & proxies
FinCEN issued an alert cautioning all FIs regarding potential investments in the U.S. commercial real estate (CRE) sector, by or on behalf of sanctioned Russian elites, oligarchs, their family members, and entities through which they act. This alert complements sustained effort…
Dutch Supreme Court judgment on intent in criminal sanctions violations
The Dutch Supreme Court confirmed that the applicable standard of proof for “intentional” violations of EU sanctions under Dutch law is generally low. The judgment confirmed that, although the intent of the accused with regard to the constituent elements of the…
EU Parliament calls for more sanctions against Iranian regime
EU Parliament urged the EU to expand its sanctions list against Iranian regime to cover all individuals and entities responsible for human rights violations and their family members. The Iranian regime’s blatant disregard for human dignity and the democratic