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FCA reviews good and poor practice with respect to firms’ response to increased sanctions due to Russia’s invasion of Ukraine

Identifies examples of both good practice and areas for improvement under 5 key themes: governance and oversight, skills and resources, screening capabilities, Customer Due Diligence (CDD) and Know Your Customer (KYC) procedures, reporting breaches to the FCA.

UK fines UK company £1 million for Russia sanctions violations

The UK Govt announced that a £1 million compound settlement was recently reached with an unnamed UK company for alleged violations of The Russian (Sanction) (EU Exit) Reg 2019. The company was reportedly fined by HMRC for engaging in the unlicensed trade of goods…

UK High Court rejects attempt by British citizen to overturn Russia-related sanctions against him

The UK High Court of Justice rejected British citizen Eugene Shvidler’s attempt to overturn sanctions imposed against him for his association with Russian oligarch Roman Abramovich.  Abramovich, the former owner of Chelsea Football Club and former partial-owner…

UK Finance requests answers to question on new UK restrictions on legal advisory services

UK Finance have collated a list of questions about the new restrictions on legal advisory services in Regulation 54D (previous post) of the Russia (Sanctions) (EU Exit) (Amendment) (No. 3) Regulations 2023, which has now been sent to the relevant government departments…

US and UK issues joint fact sheet on Russia-related sanctions to support humanitarian aid and food security

The Factsheet will provide additional clarity on Russia-related sanctions and the relevant authorizations, exceptions and public guidance issued by the US and UK. The fact sheet is intended to serve as a guide for humanitarian actors, non-governmental organizations…

New UK sanctions legislation allows the government to target Belarus exports

The measures also give the government grounds to prevent designated Belarusian media organisations from spreading propaganda in the UK, including over the internet, as the regime continues to actively facilitate Russia’s invasion of Ukraine and spread false narratives….

OFSI publishes Guidance on license applications for travel

OFSI has published guidance for applicants and potential applicants for OFSI licences relating to travel costs incurred in making their applications (for example, allowing them to attend legal meetings or court hearings). Such applications need to demonstrate that …

OFSI publishes Guidance on financial sanctions implementation for high value dealers

The Guidance is provided for entities and individuals operating in the sale or trade of high value goods, especially those trading internationally with regions that may be subject to UK financial sanctions restrictions. It covers asset freezes, reporting obligations, enforcement..

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…

 

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…