Our previous briefing commented on the recent Court of Appeal decision in Mints v PJSC National Bank Trust [2023] EWCA Civ 1132 and, particularly, the court’s consideration of the “ownership and control” test under the UK sanctions regime. In summary, the court concluded that there was no carve-out to the ownership and control test for control exercised through political office … 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

On 31 August 2023, the Office of Financial Sanctions Implementation (“OFSI“) published several updates to its Enforcement Guidance. These provide some further clarity about OFSI’s assessment of financial sanctions breaches, and approach to its power to publish details of a financial sanctions breach where it has decided not to impose any monetary penalty (a “Disclosure Report“). … Read more

The UK introduced restrictions on the provision of legal services to Russia in June 2023 (as summarised in our previous post). Since then, the legal industry has raised a number of concerns about the drafting of the relevant legislation, culminating in the issuance of a new general licence (the “GL”) which seeks to address some of … Read more

On June 28, 2023, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and His Majesty’s Treasury’s Office of Financial Sanctions Implementation (“OFSI”) published a joint Humanitarian Assistance and Food Security Fact Sheet (“Joint Fact Sheet”) that provides clarity on U.S. and UK Russia-related sanctions and the relevant authorizations, exceptions, and … Read more

Following its announcement of an 11th package of Russia sanctions in May (which we covered here), the European Union has now adopted the package. Key elements of the 11th sanctions package include fresh targeted sanctions against individuals and entities, an enlargement of restrictions on the sale, export and transit of certain goods and technology, as well as additional … Read more

In this post, we summarise recent developments regarding the UK sanctions imposed on Russia. New asset freeze designations On 19 May, the UK announced the addition of 86 further entries to its asset freeze list. The targeted individuals and entities include: individuals and entities said to be connected to the theft and resale of Ukrainian grain; companies … Read more