New sanctions reporting requirements for non-financial sector businesses

With effect from 8 August, the Government has introduced significant new reporting requirements in relation to EU asset freeze regimes. Previously, only businesses in the financial sector were subject to the obligations, found in UK financial sanctions instruments, to report specified information to the Office of Financial Sanctions Implementation (“OFSI“) in Her Majesty’s Treasury (“HMT“). … Read more

The UK Government announces consultation on sanctions post-Brexit

The two year process of the UK’s exit from the EU formally began on 29 March 2017 with notice being given under Article 50 of the Treaty on the European Union of the UK’s intention to leave the EU. One of the many legal issues to be determined will be the way in which the … Read more

EU prolongs Russian sectoral sanctions until July 2016

On 21 December, the Council of the EU announced that the EU's economic sanctions against Russia would be extended until 31 July 2016.   These measures were originally introduced for a one year period in July 2014 and were extended until 31 January 2016 in June 2015 when the EU confirmed that the duration of the … Read more

ADOPTION DAY UNDER THE IRAN AGREEMENT – US AND EU PUBLISH DETAILS OF CHANGES TO THEIR SANCTIONS REGIMES

The Joint Comprehensive Plan of Action relating to Iran's nuclear programme (the "JCPOA") officially came into effect on 18 October ("Adoption Day"), requiring all JCPOA participants to make the necessary arrangements and preparations for implementation of their respective JCPOA commitments.  In this briefing, we summarise the most recent steps taken by the US and EU … Read more

Russia-related sanctions: US Issues important advisory on ensuring compliance with Crimea sanctions regime and expands sanctions designations

The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) recently added a number of new persons and individuals to the US’s Specially Designated Nationals (“SDN”) and Sectoral Sanctions Initiative (“SSI”) lists. OFAC also issued new guidelines to strengthen compliance with the existing Crimea sanctions regime. While Treasury Department officials noted that the … Read more

High Court rules that payment under a guarantee would breach EU Libya sanctions regime, and considers contractual exemption provisions

In a recent judgment, the English High Court has considered some of the exemption language commonly found in EU sanctions regimes which is applicable to contractual performance. The case of Glenn Maud v The Libyan Investment Authority [2015] EWHC 1625 concerned an application to set aside a statutory demand for payment under a guarantee. The … Read more

Iran Sanctions Update

Further to our previous briefing, it has been announced that negotiations between the P5+1 and Iran regarding Iran’s nuclear program have been further extended and will now continue until 10 July. As with previous announcements regarding the timeframe for negotiations, no steps have yet been taken by the UN, US or EU to introduce additional … Read more