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Key Takeaways: Secondary Sanctions—United Kingdom Issues Sanctions Guidance for Non-UK Businesses

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

The FCA's Developing Approach to Nonfinancial Misconduct by Individuals in the Financial Services Sector

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

What You Need to Know About the United Kingdom Issuing Sanctions Guidance for Non-UK Businesses

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

UK Cross-Government Review of Sanctions Implementation and Enforcement

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

Key Compliance Tips on How to Respond to Information Requests From OFSI

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

The FCA's Part 2 of Its "Name and Shame" Proposals: What You Need to Know

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

New Government Guidance and UK High Court Seeks to Settle Disarray in UK Sanctions Law

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

Why Corporates Are Now More Likely to Face Criminal Prosecution for the Actions of Their Employees

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

FCA Publishes Outcome of its Review of Firms' Compliance with Sanction Controls

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

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