This alert discusses two recent significant developments at either end of the UK sanctions spectrum, covering off designation (a recent Supreme Court decision providing important guidance as to the assessment of...more
8/11/2025
/ Appeals ,
Constitutional Challenges ,
Economic Sanctions ,
Enforcement Actions ,
Human Rights ,
Judicial Review ,
Office of Financial Sanctions Implementation (OFSI) ,
Proportionality ,
Russia ,
Sanctions ,
UK ,
UK Supreme Court
On 15 May 2025, the UK Government published the conclusions of its cross-government review of UK sanctions implementation and enforcement (the Review)....more
6/19/2025
/ Customs ,
Economic Sanctions ,
Enforcement ,
Enforcement Authority ,
Financial Institutions ,
FinCEN ,
HMRC ,
Information Reports ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Prudential Regulation Authority (PRA) ,
Reporting Requirements ,
UK ,
Whistleblowers
The UK Office of Financial Sanctions Implementation (OFSI) has imposed a penalty of £465,000 on the Moscow subsidiary of Herbert Smith Freehills (HSF) for breaches of UK financial sanctions imposed on Russia following the...more
Companies faced with the decision of whether to voluntarily self-report sanctions breaches to law enforcement or sanctions enforcement agencies in the UK and the US can take some measure of comfort from recent comments made...more
10/16/2023
/ Compliance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Good Faith ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
Self-Reporting ,
Serious Fraud Office (SFO) ,
U.S. Commerce Department ,
U.S. Treasury ,
UK ,
Voluntary Disclosure
On March 1, 2022, the UK Government put forward the Economic Crime (Enforcement and Transparency) Bill. The stated aim of the legislation is to “crack down on dirty money in the UK and corrupt elites”, and it is designed to...more
3/11/2022
/ Anti-Money Laundering ,
Beneficial Owner ,
Economic Sanctions ,
Enforcement Authority ,
Financial Crimes ,
Financial Transactions ,
Money Laundering ,
Office of Financial Sanctions Implementation (OFSI) ,
Proposed Legislation ,
Real Estate Transactions ,
Real Estate Transfers ,
Registration Requirement ,
Russia ,
Unexplained Wealth Orders (UWOs)
On 15 May 2018, the UK Parliamentary Treasury Select Committee heard evidence from representatives of Transparency International, Global Witness and the RUSI Centre for Financial Crime and Security Studies as part of its...more