EU introduces new asset freezing measures against Yemen

On 19 December, the EU published Council Decision 2014/932/CFSP and Regulation 1352/2014 in relation to the situation in Yemen. The measures came into force immediately upon publication.

The new measures impose an asset freeze on three individuals: Abdullah Yahya Al Hakim, Abd Al-Khaliq Al-Huthi and Ali Abdullah Saleh. These individuals were designated on the basis that they have engaged in acts which threaten the peace, security or stability of Yemen. Continue reading

Ukraine – EU and US impose asset freeze and travel ban on Ukrainian and Russian individuals

Following the weekend’s Crimea referendum, the EU and US have taken further steps (building on those outlined in our previous briefing) to impose targeted sanctions in response to the situation in Ukraine.

On 17 March 2014, the EU introduced an asset freeze and travel ban applying to 21 Russian individuals.  On the same day, the US introduced a second Executive Order, allowing it to sanction Russian individuals and released a list of 11 Russian and Ukrainian individuals subject to an asset freeze and visa ban under its Executive orders.

For further detail, please click here for our e-bulletin on these developments.

Sanctions Update: Ukraine

Ukraine – EU imposes asset freeze on members of former government and issues a statement in relation to Russia; US introduces Executive Order permitting the blocking of assets

The EU and US have both recently taken steps to respond to recent events in Ukraine.  On 5 March 2014, the EU introduced an asset freeze applying to former President Yanukovych and other former government officials and persons associated with the former government.  The UK has introduced domestic legislation criminalising breaches of this asset freeze.  The EU also held an emergency Heads of State meeting on 6 March.  The conclusions from that meeting indicate that there is a possibility of EU sanctions being imposed on Russia in the absence of negotiations between Russia and Ukraine which produce results within a limited timeframe.  Also on 6 March the US introduced an Executive Order which would permit the imposition of an asset freeze and visa bans although no companies or individuals have yet been designated. Continue reading

Iran sanctions: Implementation of the Geneva Agreement

In November 2013, the P5+1 reached agreement on a Joint Plan of Action (JPoA) to suspend certain sanctions in exchange for Iran rolling back aspects of its nuclear programme.  On Monday 20 January 2014, the JPoA came into effect.  The EU enacted Council Regulation 2014/42 (the “Implementing Regulation”), which suspends relevant measures for a six month period.  The US Department State has also issued detailed guidance in relation to the corresponding US relaxations. Continue reading

Anti-money laundering and anti-bribery systems and controls at asset management firms: FCA thematic review

In October 2013, the Financial Conduct Authority (FCA) published the much-anticipated report of its thematic review into anti-money laundering (AML) and anti-bribery and corruption (ABC) systems and controls at asset management and platform firms.  The report follows the FSA/FCA’s previous thematic reviews of ABC controls in commercial insurance broking (2010), ABC controls in investment banks (2012), and AML and sanctions controls in trade finance (2013).  As with other thematic work, whilst the review is of a particular sector, the FCA expressly expects other regulated firms to consider the findings and examples of good and poor practice. Continue reading

Geneva Agreement – Temporary relaxation of Iran sanctions announced

In the early hours of 24 November, the P5+1 (the UK, US, Germany, France, Russia and China, facilitated by the EU) announced that they had reached a set of initial understandings with Iran. In exchange for limits on Iran’s nuclear programme, the P5+1 have given undertakings to relax sanctions, including agreeing that no new nuclear-related sanctions will be imposed for six months and that certain existing sanctions (including the restrictions on the Iranian automotive sector and petrochemical exports from Iran) will be suspended, provided Iran abides by its commitments under the deal. Please click here for our full briefing.

SFO brings first Bribery Act charges

The Serious Fraud Office (“SFO“) had its first day in court in a Bribery Act prosecution on 24 September 2013, with three of four defendants connected with a £23m fraud at Sustainable AgroEnergy plc (“AgroEnergy“) facing charges of making and accepting a financial advantage contrary to sections 1(1) and 2(1) of the Bribery Act 2010. Continue reading

Recent Sanctions Developments: EU relaxes certain Syrian sanctions and amends measures relating to North Korea, Iran and Tunisia; US relaxes Myanmar sanctions

The EU has recently published a new Regulation (Regulation 697/2013 of 22 July 2013 (“Regulation 697/2013”)) which amends Regulation 36/2012, the key piece of legislation setting out the EU’s sanctions against Syria.  In this briefing we analyse the new provisions and provide an update on other recent changes to EU and US sanctions. Continue reading

New EU Directive: Reporting by Extractive Companies on Government Payments

The European Parliament and Council of Ministers have agreed the final form of the new EU rules for the disclosure, on a project by project basis, of payments to governments by companies operating in the extractive  industries. The EU’s agreement is part of a suite of transparency initiatives which are designed to promote good governance and improved national development outcomes for developing countries.

All large companies “active” in the oil, gas and minerals industries or the logging of primary forests will be affected and the rules will apply to both EU-incorporated companies and non-EU companies that have a listing in the EU.

We have summarised in a briefing the key aspects of the new requirements, when they will come into force and how they compare with the similar requirements being introduced in the United States under the Dodd-Frank Act.

Please email Fiona Rafla if you would like a copy of this briefing.