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 … 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, … 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 (“FCA”) review of firms’ sanctions controls. UK FCA review of sanctions systems and controls On 6 September, the FCA published the results of a recent programme to assess the systems and … Read more

In a 9 May press statement President von der Leyen announced that the EU is considering a proposed eleventh package of sanctions against Russia. This update provides an overview of those proposals and a round-up of other recent sanctions developments. EU – new sanctions package In her statement, President von der Leyen confirmed that the Commission had … Read more

In this post we provide a summary of a number of recent developments regarding the UK and EU sanctions imposed on Russia. UK New UK sanctions legislation On 20 April, the UK issued its first new Russia sanctions statutory instrument of 2023: the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2023 (the “Amending Regulations”), which amend the Russia … Read more

As readers of this blog will be aware, the UK introduced restrictions on the provision of certain trust services to Russian, or Russia-connected recipients in December 2022. Those restrictions apply in respect of services provided to or for the benefit of (i) a designated person, or (ii) a person connected with Russia. For these purposes, … Read more

On 16 March, the UK’s Office of Financial Sanctions Implementation (“OFSI”) updated its guidance on monetary penalties and enforcement (the “Guidance”) to set out its enforcement approach in cases involving ownership and control by designated persons. This is an issue which has assumed increased prominence during the past year with the escalation of sanctions against Russia and … Read more