What are international sanctions? What are primary and secondary sanctions? What are extraterritorial effects and how will that impact multinational operations? The changing international sanctions regulations produce dizzying regulatory landscape, and complex as well as confusing compliance environment. To help lift the curtain a bit on this topic, Trade Practitioner José María Viñals (partner, Madrid/Brussels), also … Continue Reading
The Office of Financial Sanctions Implementation (OFSI), which is part of HM Treasury and works to ensure that financial sanctions are properly implemented and enforced in the UK, has updated a number of financial sanctions currently in force. The recent updates are as follows: Financial sanctions, Libya; Financial sanctions, Ukraine (Sovereignty and Territorial Integrity); Financial sanctions, North Korea (Democratic People’s … Continue Reading
On 19 October, the Office of Financial Sanctions Implementation (OFSI) published new guidance and a FAQs factsheet to assist charities and NGOs to understand their obligations under financial sanctions and the OFSI’s approach to licencing and compliance issues.… Continue Reading
The UK Joint Money Laundering Steering Group (JMLSG) has published proposed revisions to its guidance on the prevention of money laundering and the financing of terrorism for the UK financial services industry. The revisions reflect a number of factors, including the provisions of the proposed new Money Laundering Regulations published by HM Treasury on 15 … Continue Reading
On 29 May, the Council of the European Union adopted Council Implementing Regulation 2017/904, which implements Regulation (EC) No 1183/2005. With respect to the Democratic Republic of Congo, asset freezes now apply to nine individuals, which can be found in the Annex of Council Implementing Regulation 2017/904. The Office of Financial Sanctions Implementation’s (OFSI) notice … Continue Reading
Following the coming into force of Part 8 of the Policing and Crime Act 2017, which introduces new monetary penalties for breaches of financial sanctions, OFSI has published guidance on the new regime, including: Guidance on monetary penalties for breaches of financial sanctions A response to OFSI’s consultation on the process for imposing monetary penalties … Continue Reading
On 1 April 2017, HM Treasury implemented a new US-type financial sanctions enforcement framework, The Policing and Crime Act (the Act), that can potentially fine UK and non-UK companies EUR 1 million or more for breaches of financial sanctions. Part 8 of the Act gives the Office of Financial Sanctions Implementation (OFSI), which is part of HM … Continue Reading
The Office of Financial Sanctions Implementation (OFSI) is currently consulting on its draft guidance on monetary penalties for breaches of financial sanctions within the context of new civil powers in the Policing and Crime Act 2017. This guidance sets out how OFSI will assess whether to impose monetary penalties and how those penalties will be … Continue Reading
OFSI has updated its sanctions guidance in order to include a section on travel to the UK. The new guidance announces that all designated people who are planning to visit the UK, as well as people being funded by a designated person, must hold an appropriate licence to support themselves while in the country that … Continue Reading
The two-part guidance provides a general overview of the application of the UK’s financial sanctions framework, as well as providing practical examples of how the OFSI will generally approach licencing and compliance questions.… Continue Reading
In a bid to bring the UK in line with the US Treasury Department’s Office of Foreign Assets Control (OFAC), the UK government has proposed a significant increase in the effectiveness of sanction enforcement powers. Legislation was put before parliament in February in the form of the Policing and Crime Bill. The new legislation would increase the available prison … Continue Reading