On March 20, 2025, the U.K.’s Office of Financial Sanctions Implementation (OFSI) announced that, in accordance with section 146 of the Policing and Crime Act 2017 (PACA), a monetary penalty of £465,000 had been imposed...more
3/27/2025
/ Compliance ,
Due Diligence ,
Economic Sanctions ,
Enforcement Actions ,
Office of Financial Sanctions Implementation (OFSI) ,
Penalties ,
Regulatory Requirements ,
Reporting Requirements ,
Risk Management ,
Russia ,
UK
On 11 March 2025, the Department for Business and Trade through the Export Control Joint Unit (ECJU), issued a notice to exporters providing advance notice of updates to the UK Strategic Export Control Lists, which are...more
Background - The war in Ukraine has taken a new diplomatic turn in recent weeks. Having historically aligned with the European Union (EU) and United Kingdom (UK) on its condemnation of Russia’s war in Ukraine, and the need...more
3/17/2025
/ Asset Freeze ,
Economic Sanctions ,
EU ,
Foreign Policy ,
Foreign Relations ,
International Trade ,
National Security ,
NATO ,
Russia ,
UK ,
Ukraine ,
United States
Scottish chip firm loses temporary injunction application for relief while divestment decision is challenged by judicial review, following the UK issuing its third Annual Report on the NSIA. The UK High Court of Justice has...more
Key Takeaways - On 12 September 2024, the UK government published the Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 (the “Regulations”), which will come into force on 10 October 2024. The...more
Key Takeaways - On 3 July 2024, the Council of the European Union (the “EU Council”) published its revised Update of the EU Best Practices for the effective implementation of restrictive measures (“Best Practices”).This...more
7/23/2024
/ Best Practices ,
Buyback Programs ,
Economic Sanctions ,
EU ,
Limited Liability Company (LLC) ,
Majority Shareholders ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Shell Corporations ,
Trusts ,
UK
Key Points - Following our Alert last month addressing the United Kingdom Government’s intentions to improve the workings of the National Security and Investment Act 2021 (NSIA), the U.K. Government has now published two new...more
5/28/2024
/ Acquisitions ,
Foreign Direct Investment ,
Foreign Investment ,
Insolvency ,
Intellectual Property Protection ,
Investment ,
National Security ,
Restructuring ,
Risk Assessment ,
Supply Chain ,
UK
Key Points - On Thursday, the UK government announced its intention to improve the workings of the NSIA, “ in these dangerous and uncertain times [when] our economy is increasingly the target for our adversaries.” In November...more
On 11 March 2024, the UK expanded its export control regime to include new controls on specific emerging technologies, such as quantum computing, semiconductor technologies and additive manufacturing, under The Export Control...more
EU’s 12th Sanctions Package - On 19 December 2023, the Council of the European Union (EU) together with the Commission published its 12th round of sanctions....more
12/27/2023
/ Asset Freeze ,
Banking Sector ,
Cryptocurrency ,
Economic Sanctions ,
EU ,
European Economic Area (EEA) ,
Export Controls ,
Fund Transfers ,
G7 ,
Imports ,
Information Sharing ,
Insurance Industry ,
Licensing Rights ,
Metals ,
Oil Prices ,
Pipelines ,
Propane ,
Reporting Requirements ,
Russia ,
SDN List ,
Software ,
Technology Sector ,
Telecommunications ,
Trade Restrictions ,
Transparency ,
UK
The UK announced that it will require importers to pay a carbon levy on certain goods imported from countries with a lower or no carbon price.
Covered goods under the UK’s carbon border adjustment mechanism (CBAM) likely...more
Key Takeaways -
On 17 November 2023, the Foreign, Commonwealth & Development Office (FCDO) and Office of Financial Sanctions Implementation (OFSI) published new guidance on Ownership and Control: Public Officials and...more
The United Kingdom just issued a new statutory instrument, effective immediately, which extends the authority to designate persons and entities under the U.K. sanctions against Russia.
Previously, the U.K. government...more
Key Points -
The proposed power would allow the UK Government to block initial equity listings and admissions on UK public markets on the grounds of national security.
The listing of debt securities (other than...more
While the U.K. has a mature approach to protecting national security overall, the government lacks effective statutory powers in relation to the ownership and control of businesses and other entities that could be used to...more
The U.K. and the EU conclude the EU-UK Trade and Cooperation Agreement, which entered into force on December 31, 2020.
The Agreement provides guidance on origin rules that must be met for products to benefit from duty-free...more
1/8/2021
/ Cooperation Agreement ,
Country of Origin ,
EU ,
Export Controls ,
Exports ,
Member State ,
Regulatory Standards ,
Supply Chain ,
Trade Agreements ,
Trade Relations ,
UK ,
UK Brexit
1. Summary
The United Kingdom (U.K.) government published the National Security and Investment Bill (“NSI Bill” or “Bill”) on November 11, 2020, the aim of which is to strengthen the government’s powers to scrutinize and...more
- There is increasing regulatory, commercial and media attention in the U.K. and the EU regarding the role of human rights in company supply chains.
- The U.K. and the EU are introducing specific measures around human...more
7/22/2020
/ Coronavirus/COVID-19 ,
Due Diligence ,
Environmental Social & Governance (ESG) ,
EU ,
Forced Labor ,
Human Rights ,
Investors ,
Modern Slavery Act ,
Proceeds of Crime Act 2002 (POCA) ,
Risk Assessment ,
Risk Mitigation ,
Slavery ,
Supply Chain ,
UK
- As of 1:00 p.m. BST July 6, 2020, the GHR Regulation came into force, representing the introduction of the U.K.’s long awaited GHR Regime.
- The GHR Regime is the first standalone U.K. sanctions regime to be in current...more
- On April 21, 2020, Imagination Technologies, a U.K. based company producing graphics processing units used in 11 billion devices globally, was summoned to answer questions by MPs in relation to national security concerns....more
• The White Paper sets out in detail the shape and scope of the U.K.’s desired future “association” relationship with the EU post Brexit. The U.K. government hopes that it will accelerate negotiations with the EU with a view...more
• The U.K. and the EU have agreed on the substantive trade elements of the legal text set to govern the U.K.’s withdrawal from the EU (the “Withdrawal Agreement”). If the other outstanding elements of the Withdrawal Agreement...more
3/28/2018
/ Cross-Border Transactions ,
EU ,
EU Single Market ,
Free Trade Agreements ,
Intellectual Property Protection ,
International Relations ,
Member State ,
Referendums ,
Trade Policy ,
Trade Relations ,
UK ,
UK Brexit
In an important decision given on February 21, 2018, a jury in English court proceedings has considered for the first time what “adequate procedures” should be for the purpose of a defense to the corporate offense of failing...more
3/13/2018
/ Anti-Bribery ,
Bribery ,
Corporate Counsel ,
Corporate Liability ,
Criminal Convictions ,
Criminal Liability ,
Criminal Prosecution ,
Deferred Prosecution Agreements ,
Jury Verdicts ,
National Crime Agency (NCA) ,
Policies and Procedures ,
Section 7 ,
Self-Reporting ,
UK ,
UK Bribery Act