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  • UK Government seeks to allay sanctions control concerns after court judgment

    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

  • When diamonds aren’t a girl’s (or boy’s) best friend

    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

  • FCA identifies areas for improvement in firms’ sanctions controls

    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

  • 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

  • £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

  • UK’s OFSI to return incomplete licence applications

    Last week OFSI announced in their blog that it will start to return specific licence applications that are submitted in an incomplete format.  Anyone who has submitted a financial licence application to OFSI will know that turnaround times are long – even where a licence is considered urgent it can take some months to receive Read more