In R. (on the application of Mikhail Fridman) v HM Treasury [2023] EWHC 2657 (Admin) the High Court dismissed all grounds of challenge raised by an individual designated under the sanctions regime. In doing so the court made comments on the proper role of judicial review and evidence in such proceedings, in keeping with the recent trend of insisting on procedural rigour in public law cases. Read more

Our previous briefing commented on the recent Court of Appeal decision in Mints v PJSC National Bank Trust [2023] EWCA Civ 1132 and, particularly, the court’s consideration of the “ownership and control” test under the UK sanctions regime. In summary, the court concluded that there was no carve-out to the ownership and control test for … Read more

The Court of Appeal has confirmed that UK sanctions do not preclude the entry of judgments in favour of Russian sanctioned parties: Mints v PJSC National Bank Trust [2023] EWCA Civ 1132. The court also held that the Office of Financial Sanctions Implementation (OFSI) is entitled to license a sanctioned party to pay an adverse costs order, security for costs or damages on a cross-undertaking in damages. It can also license payment of a costs order in favour of a sanctioned party. Read more

In this post, we provide a round-up of key recent Russia sanctions developments in the UK and EU, including the findings from the Financial Conduct Authority's review of firms' sanctions controls. Read more

The UK introduced restrictions on the provision of legal services to Russia in June 2023 (as summarised in our previous post). Since then, the legal industry has raised a number of concerns about the drafting of the relevant legislation, culminating in the issuance of a new general licence (the "GL") which seeks to address some of the most significant unintended consequences arising from the new restrictions. In this post, we review the provisions of the GL and the remaining issues with these restrictions, as well as providing a round-up of key recent Russia sanctions developments in the UK and EU. Read more

The UK's long-awaited sanctions restricting the provision of legal services to Russia were announced on 29 June. The announcement gives a somewhat misleading impression of the law, and we summarise the new restrictions in this post. The new measures are introduced by the Russia (Sanctions) (EU Exit) (Amendment) (No. 3) Regulations 2023 (the "Amending Regulations"), which amend the Russia (Sanctions) (EU Exit) Regulations 2019 (the "Russia Regulations"). Read more

Following its announcement of an 11^th package of Russia sanctions in May (which we covered here), the European Union has now adopted the package. Key elements of the 11^th sanctions package include fresh targeted sanctions against individuals and entities, an enlargement of restrictions on the sale, export and transit of certain goods and technology, as well as additional measures to prevent sanctions circumvention.  We summarise the key elements in this post, along with a round-up of other recent sanctions developments from the UK. Read more

In this post, we summarise recent UK and EU developments regarding sanctions. Read more