OFSI updates guidance on enforcement and monetary penalties for financial sanctions breaches and publishes first breach report without imposing a monetary penalty

On 31 August 2023, the Office of Financial Sanctions Implementation ("OFSI") published several updates to its Enforcement Guidance. These provide some further clarity about OFSI's assessment of financial sanctions breaches, and approach to its power to publish details of a financial sanctions breach where it has decided not to impose any monetary penalty (a "Disclosure Report"). Read more

OFSI updates its enforcement guidance regarding ownership and control by sanctioned persons

On 16 March, the UK's Office of Financial Sanctions Implementation ("OFSI") updated its guidance on monetary penalties and enforcement (the "Guidance") to set out its enforcement approach in cases involving ownership and control by designated persons. This is an issue which has assumed increased prominence during the past year with the escalation of sanctions against Russia and the huge number of additional asset freeze designations made as a result. This has resulted in many companies analysing whether their counterparties may be deemed to be "owned or controlled" by a sanctions target – a question to which there is often no easy answer. Read more

When the Hong Kong Stock Exchange knocks, open the door and cooperate

The Stock Exchange of Hong Kong Limited (SEHK) recently published its new Guidance Note on Cooperation (Cooperation Note) and revised Enforcement Sanctions Statement (Sanctions Statement). The Cooperation Note is a brand new guidance note that stresses SEHK’s expectations regarding cooperation. It sets out examples of good cooperation with the possible benefits and examples of uncooperative conduct with the possible consequences. Read more

Global FSR Outlook 2023 – Braving the maelstrom

Our Global FSR Outlook 2023 has been published.  In the Outlook, our Financial Services Regulatory (FSR) team surveys the regulatory landscape for 2023 and considers the challenges confronting firms and regulators. Read more