Sanctions tracker – new UK trade sanctions

This briefing summarises the new Russia sanctions measures introduced by the UK on 23 June 2022 and provides a round-up of other key UK and EU developments since our last sanctions tracker post. Read more

Proposed amendments to MLRs – New change in control regime for cryptoasset businesses

At the moment, the FCA's only powers over crypto businesses which do not carry on investment, payment services, e-money or other UK regulated business come from its role as their anti-money laundering and counter-terrorist financing supervisor. This will change in due course in respect of stablecoin businesses (with HMT consulting on bringing these into scope) and in respect of financial promotions of certain cryptoassets (both HMT and FCA are consulting on this). Read more

Strict liability test for sanctions breaches come into force

Changes to the UK's financial sanctions regime, introduced by the Economic Crime (Transparency and Enforcement) Act 2022 (the "Act"), came into force today (15 June 2022) and, with them, the power for the Office of Financial Sanctions Implementation ("OFSI") to impose civil monetary penalties in respect of financial sanctions breaches on a strict liability basis (i.e. irrespective of any knowledge or suspicion). Read more