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A numerical tour of OFSI’s Annual Review
As active watchers of UK sanctions will be aware, the UK’s Office of Financial Sanctions Implementation (OFSI), published its annual report for 1 Apr 2022 – 31 Mar 2023 just before Christmas. You can read the full report here. I’m a numbers guy at heart and here are the key areas that tell the story… Read more
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UK Government seeks to allay sanctions control concerns after court judgment
The UK Government has issued a holding statement in response to the recent Court of Appeal judgment in Mints & others v PJSC National Bank Trust & another. This judgment suggested any company in Russia could be sanctioned because President Putin is subject to an asset freeze. What was the issue? While the issue did… Read more
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When diamonds aren’t a girl’s (or boy’s) best friend
How a G7 ban on Russian diamond imports will not be a game-changer, but may well complicate compliance for EU operators. There is increased talk of the G7 announcing a new ban on the import of Russian diamonds, which would further harmonise a number of countries’ sanctions regimes. The US, UK, Canada and Australia already… Read more
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FCA identifies areas for improvement in firms’ sanctions controls
The UK’s Financial Conduct Authority has been making waves with regulated firms’ sanctions compliance following the publication of a new report and a speech given by Sarah Pritchard at the 1LOD Financial Crime Summit. The FCA assessed sanctions controls at 90 financial services firms and have announced their findings. The least-surprising observation is the FCA… Read more
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Wise Payments is first target of OFSI’s ‘name and shame’ powers
A week after we saw the first Russia trade sanctions breach enforcement from the UK’s HM Revenue & Customs, OFSI has used new powers to report on a financial sanctions breach, while levying no monetary penalty. OFSI announced that Wise Payments Limited, a regulated financial services business, had breached Russian financial sanctions by allowing an… Read more
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£1m sanctions penalty highlights fragmentation of UK enforcement
An unidentified UK company has been fined £1m by HM Revenue & Customs in what may be considered a trail-blazing settlement: The joint statement by the Department for Business & Trade (“DBT”), the Foreign & Commonwealth Development Office (“FCDO”) and HM Revenue & Customs (“HMRC”) states simply “In August 2023, a UK company was fined… Read more

