US Treasury, Commerce Department Sanction Hundreds of Individuals and Entities in Reaction to Navalny Death, Russian Invasion of Ukraine

    On February 23, 2024, the US Treasury’s Office of Foreign Assets Control (“OFAC”) and the Commerce Department’s Bureau of Industry and Security (“BIS”) sanctioned nearly 300 individuals and entities in relation to their operations associated with Russia’s invasion of Ukraine. Together with actions from the US Department of State, this marks the largest number of … Read more

    OFAC PUBLICATION OF PRICE CAP COALITION ALERT

    On February 1, 2024, the United States Department of Treasury’s Office of Foreign Assets Control (“OFAC”) published a Price Cap Coalition Compliance and Enforcement Alert (the “Alert”). Per the Alert, the “Price Cap Coalition,” which consists of the G7, the European Union, and Australia, has two key objectives: (1) constraining Russian revenues that could otherwise … Read more

    OFAC Makes Further Iran-related Designations, Counter Terrorism Designations

    The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) on January 30, 2024, designated two cybersecurity experts affiliated with the Islamic State of Iraq and Syria (“ISIS”) for providing ISIS leadership and supporters with cybersecurity training, enabling their use of virtual currency, and supporting the terrorist group’s recruitment. Additionally, OFAC designated an … Read more

    The EU Anti Money Laundering Authority and the AML reform package: an update

    In July 2021, the European Commission presented a package of legislative proposals designed to combat money laundering, terrorist financing and the evasion of sanctions. These proposals included the establishment of a new EU agency, the Anti Money Laundering Authority (AMLA). On 13 December 2023, the EU Parliament and Council of the EU announced that they had reached a “provisional agreement” on … Read more

    OFSI publishes Annual Review 2022-23

    On 14 December 2023, HM Treasury’s Office of Financial Sanctions Implementation (“OFSI“) published its Annual Review for the 2022-23 financial year (the “Annual Review“). As expected, the Annual Review predominantly focuses on the UK sanctions imposed against Russia following its invasion of Ukraine in February 2022. However, the publication also provides an overview of the other work … Read more

    US Treasury Enacts Major New Beneficial Ownership Disclosure Requirements for US and International Companies

    In an action with major implications for non-US companies doing business in the United States, January 1, 2024, was the effective date for a sweeping new set of company ownership disclosure requirements, requiring disclosure of beneficial ownership of a wide range of entities to the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”). … Read more

    High Court dismisses force majeure and trade sanctions defences in breach of contract claim, and considers “ownership and control” test under UK sanctions

    The High Court has allowed a summary judgment application in relation to a breach of contract claim, finding that there was no realistic prospect of the defendants being able to rely on force majeure and change of trade sanctions provisions in the agreement: Litasco SA v Der Mond Oil and Gas Africa SA & Anor (Rev1) [2023] … Read more

    OFAC TIGHTENS PRICE CAP WITH NEW SANCTIONS AND IMPOSES SANCTIONS ON MORE THAN 150 INDIVIDUALS AND ENTITIES SUPPLYING RUSSIA’S MILITARY-INDUSTRIAL BASE

    On December 20, 2023, the United States Department of Treasury’s Office of Foreign Assets Control (“OFAC”) tightened enforcement of the price cap on Russian oil. OFAC, in coordination with the Price Cap Coalition, updated the Guidance on Implementation of the Price Cap Policy for Crude Oil and Petroleum Products of Russian Federation Origin, implementing more … Read more