US Senate Calls for Designation of Russia as a “State Sponsor of Terrorism”

On July 27, 2022, the US Senate unanimously passed a nonbinding, bipartisan resolution to designate the Russian Federation as a “State Sponsor of Terrorism” (SST).  In parallel, a bipartisan group of members of the US House of Representatives introduced a bill on July 28, 2022 to designate Russia as an SST.  See H.R.8568.  These actions … Read more

Russian sanctions evasion – key indicators for regulated firms

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

Sanctions Tracker – Further U.S. Responses to the Crisis in Ukraine

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

Sanctions tracker: further UK and EU sanctions measures introduced

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

OFAC Issues a Finding of Violation to MidFirst Bank for Violations of the Weapons of Mass Destruction Proliferators Sanctions Regulations

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

Sanctions Tracker – Further U.S. Responses to the Crisis in Ukraine

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