Our previous blogpost mentioned the recent red alert on sanctions evasion typologies issued by various law enforcement and financial sector partners. In this post we look at this update in more detail to identify potential indicators of sanctions evasion, and the steps that the alert indicates that financial sector and other anti-money laundering (“AML”) regulated firms should … Read more

The U.S. government has continued to impose additional Russia-related sanctions measures in response to Russia’s invasion of Ukraine. We previously discussed Russia-related sanctions and export control measures imposed by the U.S. on July 7, July 6, June 13, and in earlier posts. In the U.S. Department of the Treasury’s Office of Foreign Assets Control’s (“OFAC”) … Read more

New Russian sanctions measures have continued to be introduced in the last few days. In this update, we summarise the UK’s new sanctions legislation in relation to Russian gold, coal and oil and the provision of services (among other things), as well as the EU’s new “maintenance and alignment” sanctions package. UK  New UK legislation … Read more

On July 21, 2022, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury issued a Finding of Violation (“FOV”) to MidFirst Bank (“MidFirst”) for violations of the Weapons of Mass Destruction Proliferators Sanctions Regulations (“WMDPSR”). The violations stemmed from MidFirst’s maintaining of accounts for and processing of 34 payments on behalf of individuals added to the OFAC’s … Read more

This update contains a round-up of recent EU and UK Russia sanctions developments. In particular, we look at a raft of new UK sanctions legislation, as well as other developments in both jurisdictions. UK New sanctions legislation The UK has published three sets of amending regulations in relation to its Russia sanctions legislation: the Russia … Read more

This post provides an update regarding further Russia-related sanctions measures in the United States. New General Licenses On June 28, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued several new General Licenses (“GLs”): GL 39 authorizes certain transactions ordinarily incident and necessary to the wind down of any transaction … Read more

On June 30, 2022, Assistant Secretary of Commerce for Export Enforcement Matthew S. Axelrod published a memorandum that outlines four “significant policy changes” that the Bureau of Industry and Security (“BIS”) of the US Department of Commerce is making to enhance its enforcement of US export controls (the “Axelrod Memorandum”). Some of the announced “policy … Read more

On June 21, 2022, U.S. Customs and Border Protection (“CBP”) began enforcing the Uyghur Forced Labor Prevention Act (Pub. L. 117-78) (the “UFLPA”), which establishes a “rebuttable presumption” that goods produced wholly or in part in the Xinjiang Uyghur Autonomous Region (“XUAR”) in China or by certain identified entities are made with forced labor, and … Read more