The U.S. Department of the Treasury (“Treasury”) Office of Foreign Assets Control (“OFAC”) has designated the Nicaraguan mining authority General Directorate of Mines (“DGM”), as well as Reinaldo Gregorio Lenin Cerna Juarez, an official of the Government of Nicaragua, pursuant to Executive Order (“E.O.”) 13851. DGM is being designated for being owned or controlled by … Read more

On 6 October, the EU agreed its eighth Russia sanctions package (initial details of which were set out in our previous blogpost). The Commission and the Council have both issued press releases in connection with the new measures and the Commission has also published a Q&A on the new measures. The new sanctions package comprises the following key elements: additional asset freeze … Read more

On September 23, G7 Leaders issued a statement condemning Russia’s recent attempts to annex parts of Ukrainian territory. In support of the statement, the US Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued a Russia-related guidance that warns of the heighted sanctions risk that international actors outside of Russia would face for providing … Read more

The finance ministers from the Group of Seven major economies (“G-7”) have issued a plan to impose a cap on the price importers pay for Russian oil, in a bid to shrink a key source of revenue the Kremlin uses to finance its war in Ukraine. As described in the G-7 statement, the G-7 countries, … Read more

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

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

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