On 22 July 2025, the UK’s Office of Financial Sanctions Implementation (OFSI) launched a major consultation proposing wide-ranging enhancements to its civil enforcement framework (the Consultation). The Consultation is open...more
On 14 July 2025, the United Kingdom’s Foreign, Commonwealth and Development Office released important sanctions guidance aimed specifically at non-UK companies operating outside the United Kingdom, with a special focus on...more
On 18 June 2025, the UK Office for Financial Sanctions Implementation (OFSI) released a Threat Assessment (the Assessment) targeting Art Market Participants (AMPs) and High-Value Dealers (HVDs). This follows new rules from 14...more
7/23/2025
/ AML/CFT ,
Anti-Money Laundering ,
Art ,
Due Diligence ,
Economic Sanctions ,
Financial Crimes ,
Fine Art ,
Office of Financial Sanctions Implementation (OFSI) ,
Reporting Requirements ,
Risk Management ,
UK
On 2 July 2025, the United Kingdom (UK) Financial Conduct Authority (FCA) published a Consultation Paper and Policy Statement (CP25/18) on tackling non-financial misconduct in financial services....more
The United Kingdom’s Foreign, Commonwealth and Development Office has published guidance on United Kingdom’s Russia sanctions compliance for non-UK businesses operating outside the United Kingdom (the Guidance). It also...more
On 18 June 2025, the UK Office for Financial Sanctions Implementation (OFSI) published a threat assessment (the Assessment) on compliance with UK sanctions and money laundering law for art market participants (AMPs) and high...more
7/15/2025
/ AML/CFT ,
Anti-Money Laundering ,
Art ,
Beneficial Owner ,
Digital Assets ,
Due Diligence ,
Economic Sanctions ,
Money Laundering ,
Office of Financial Sanctions Implementation (OFSI) ,
Penalties ,
Reporting Requirements ,
Risk Assessment
Following a two-part consultation, which began in February 2024 (i.e., CP 24/2 and CP 24/2: Part 2) and was accompanied by a Policy Statement (PS25/5) setting out the UK Financial Conduct Authority’s (FCA) consultation...more
On 15 May 2025, the UK government published a policy paper summarising findings from a cross-government review of sanctions implementation and enforcement. The Foreign, Commonwealth and Development Office led the review in...more
On 8 May 2025, the United Kingdom’s Office of Financial Sanctions Implementation (OFSI) of HM Treasury published a penalty notice regarding a breach of financial sanctions by a UK registered company—Svarog Shipping & Trading...more
5/30/2025
/ Compliance ,
Economic Sanctions ,
Enforcement Actions ,
Financial Crimes ,
Financial Institutions ,
Government Agencies ,
Office of Financial Sanctions Implementation (OFSI) ,
Penalties ,
Reporting Requirements ,
Request For Information ,
UK
In a bid to further increase the pressure on Russia, the Council of the European Union has adopted additional measures which have been introduced in its 16th sanctions package. The new measures amending the framework Council...more
The United Kingdom’s Serious Fraud Office (SFO) recently published updated guidance on how corporates can best avoid or reduce the risk of prosecution in cases involving economic crimes such as bribery, fraud and corruption...more
The United Kingdom’s Office of Financial Sanctions Implementation (OFSI) has published a report detailing suspected breaches of UK financial sanctions involving UK property and related services firms since February 2022 and...more
4/28/2025
/ Anti-Money Laundering ,
Beneficial Owner ,
Economic Sanctions ,
Landlords ,
Money Laundering ,
Office of Financial Sanctions Implementation (OFSI) ,
Property Owners ,
Real Estate Transactions ,
Reporting Requirements ,
Suspicious Activity Reports (SARs) ,
UK
In its first-ever threat assessment of the UK legal sector, the UK’s Office of Financial Sanctions Implementation (OFSI) has raised red flags with regards to suspected sanctions breaches involving UK legal services providers...more
The UK’s Financial Conduct Authority had proposed a so-called “name and shame” approach that would have allowed it, subject to certain safeguards, to disclose its investigations into firms publicly at an early stage (see our...more
The United Kingdom’s Financial Conduct Authority (FCA) has announced significant changes to its regulatory approach, including dropping the obligation to “name and shame” firms under investigation, dropping the proposed...more
On 13 February 2025, the Office of Financial Sanctions Implementation (OFSI) published its assessment of suspected sanctions breaches involving financial services firms since February 2022 (the Assessment). The Assessment...more
On 24 February 2025, the European Union adopted the 16th Russia sanctions package. The new measures amending the framework Council Regulation (EU) 833/2014 are found and included in Council Regulation (EU) 2025/395. They...more
On 24 June 2024, the European Union (EU) implemented its 14th package of sanctions against Russia to combat its continued aggression against Ukraine. A notable addition was made to Article 8a of Council Regulation (EU) No...more
In November 2024, the UK FCA released a Consultation which seeks to clarify its proposed approach to publicising ongoing enforcement action—dubbed the “name and shame” plan—and to assure the wider market of the plan’s...more
On 27 February 2024, the Financial Conduct Authority (FCA) published its Consultation Paper CP24/2, which revealed the FCA’s new intended approach to publicised enforcement action. This was quickly dubbed the “name and shame”...more
On 24 June 2024, the European Union (EU) implemented its 14th package of sanctions against Russia to combat its continued aggression against Ukraine. The package introduced new anti-circumvention measures to strengthen...more
On 6 November 2024, the government released its much-anticipated guidance on the offence of failure to prevent fraud (the Guidance), as introduced by the Economic Crime and Corporate Transparency Act 2023 (the Act)....more
Background - The Economic Crime and Corporate Transparency Act (2023) (the Act) introduces the most significant changes to Companies House since corporate registrations were established in 1844. It is a new UK law that aims...more
The Financial Conduct Authority (FCA) recently levied a jaw-dropping £29 million fine against Starling Bank (Starling). The fine follows an investigation by the regulator, which exposed the bank's "shockingly lax" sanctions...more
On 24 September 2024, the G7 released updated guidance on the prevention of evasion of export controls and sanctions imposed on Russia. The aim of the guidance is to “assist industry in identifying Russian evasion practices...more