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 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
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
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
On 12 September 2024, the UK government released the new Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 (the Regulations), which will come into force on 10 October 2024. The Regulations grant the...more
The Impact of the EU and UK Russian Sanctions Regime on the Luxury Goods Sector - As the EU and UK Russian sanctions regimes continue to evolve, export controls are now affecting industries previously not often subject to...more
The following alert provides an update on recent sanctions developments, including: The publication of the UK government’s first sanctions strategy. The announcement of over 50 new sanctions. Measures to strengthen the Oil...more
4/12/2024
/ Asset Freeze ,
Economic Sanctions ,
EU ,
Export Controls ,
Exports ,
Imports ,
New Regulations ,
Oil & Gas ,
Regulatory Oversight ,
Russia ,
Sanctions and Anti-Money Laundering Act 2018 (SAMLA) ,
Trade Relations ,
UK
In October, the Court of Appeal suggested all companies operating in Russia could be considered to be sanctioned under UK law because they are potentially controlled by President Putin. This caused understandable alarm to...more
Significant Expansion to Corporate Criminal Liability Becomes Law in the United Kingdom - On 26 October 2023, the Economic Crime and Corporate Transparency Act (the Act) became law. Under the Act, corporations will become...more
11/21/2023
/ Bribery ,
Compliance ,
Corporate Liability ,
Corporate Transparency Act ,
Criminal Liability ,
Criminal Prosecution ,
Due Diligence ,
Fraud ,
Money Laundering ,
Risk Assessment ,
Senior Managers ,
UK ,
White Collar Crimes
A non-binding passage in a recent Court of Appeal judgment has suggested that any company based in or incorporated in Russia could be subject to the same UK sanctions as Vladimir Putin. The UK Foreign, Commonwealth and...more
Introduction - Since the Russian invasion of Ukraine in February 2022 the UK has introduced an unprecedented number and variety of sanctions. The FCA has recently assessed the sanctions controls of over 90 financial service...more
July was another busy month for sanctions in the United Kingdom. We have prepared a briefing on the key recent developments and suggested practical steps for companies and legal professionals to assist in understanding the...more