- What is new: UK Russian sanctions were strengthened with new designations and a reduced oil price cap. The government also published its cryptoassets threat assessment, issued guidance on sanctions for non-UK businesses and...more
7/30/2025
/ Cryptoassets ,
Due Diligence ,
Economic Sanctions ,
Energy Sector ,
Enforcement ,
Export Controls ,
Financial Regulatory Reform ,
Financial Services Industry ,
Oil & Gas ,
Russia ,
Sanctions ,
UK
The EU and UK sanctions regimes on Russia continue to expand as both jurisdictions seek to increase pressure on President Putin. As with previous recent packages, Russia’s military, energy and financial sectors have again...more
6/3/2025
/ Economic Sanctions ,
Enforcement Actions ,
EU ,
European Commission ,
Export Controls ,
HM Treasury ,
National Security ,
Office of Financial Sanctions Implementation (OFSI) ,
Russia ,
Sanctions ,
UK
The Offence and Penalty -
On 8 May 2025, the UK’s Office of Financial Sanctions Implementation (OFSI) published its 11 April 2025 notice of its first-ever monetary penalty for an information offence relating to financial...more
5/19/2025
/ Civil Monetary Penalty ,
Compliance ,
Corporate Counsel ,
Corporate Governance ,
Disclosure Requirements ,
Economic Sanctions ,
Enforcement Actions ,
National Security ,
Office of Financial Sanctions Implementation (OFSI) ,
Penalties ,
Reporting Requirements ,
Russia ,
UK
The UK’s sanctions regimes remain dynamic as they continue to respond to geopolitical changes. In recent weeks, the UK has enhanced its Russia sanctions, despite the uncertain direction of the international sanctions on...more
5/7/2025
/ Anti-Corruption ,
Compliance ,
Criminal Prosecution ,
Economic Sanctions ,
Enforcement Actions ,
EU ,
Export Controls ,
HM Treasury ,
National Security ,
Office of Financial Sanctions Implementation (OFSI) ,
Risk Management ,
Russia ,
Syria ,
UK
On 1 April 2025, the UK government confirmed that the Foreign Influence Registration Scheme (FIRS) — which was established under the National Security Act 2023 — will come into force from 1 July 2025. The UK government has...more
The European Union (EU) has reaffirmed its sanctions policy toward Russia by implementing two rounds of restrictive measures that are intended to further intensify pressure on Russia’s government and economy. Specifically,...more
3/18/2025
/ Asset Freeze ,
Compliance ,
Economic Sanctions ,
Energy Sector ,
Enforcement Actions ,
EU ,
European Commission ,
Export Bans ,
Export Controls ,
Financial Institutions ,
International Trade ,
National Security ,
Oil & Gas ,
Regulatory Agenda ,
Russia ,
UK ,
Ukraine
The future of international sanctions on Russia is not settled. Whilst the representatives of the US and Russia met in Saudi Arabia on 18 February 2025 to discuss possible avenues to peace in Ukraine, the foreign ministers of...more
2/25/2025
/ Anti-Money Laundering ,
Compliance ,
Cryptocurrency ,
Enforcement Actions ,
EU ,
Financial Institutions ,
Financial Services Industry ,
Popular ,
Russia ,
Sanctions ,
UK
On 6 November 2024, the UK government published its guidance on the new ‘failure to prevent fraud’ offence, which was introduced in the Economic Crime and Corporate Transparency Act 2023 (ECCTA 2023).1 We covered the details...more
The past weeks and months have brought about tremendous political change in the West, as we move toward a new U.S. administration, a new College of Commissioners in Brussels and a new Polish presidency of the Council of the...more
11/13/2024
/ Capital Markets ,
CFIUS ,
China ,
Corporate Counsel ,
Economic Sanctions ,
Enforcement Actions ,
EU ,
Export Controls ,
Extraterritoriality Rules ,
Financial Institutions ,
Middle East ,
National Security ,
Regulatory Requirements ,
Russia ,
Sanctions ,
Tariffs ,
Trump Administration ,
UK ,
Ukraine ,
US Trade Policies ,
Whistleblowers
On 27 September 2024, the UK’s financial sanctions regulator, the Office of Financial Sanctions Implementation (OFSI), announced that it had issued its first monetary penalty for a breach of UK financial sanctions imposed...more
On 12 September 2024, the UK government published The Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 (Regulations) which, among other things, set out the powers of the new Office of Trade...more
9/25/2024
/ Economic Sanctions ,
Enforcement Actions ,
Financial Regulatory Reform ,
International Trade ,
New Legislation ,
New Regulations ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements ,
Sanctions ,
Trade Policy ,
UK
When the UK Modern Slavery Act 2015 (Act) came into force, it was considered a landmark legal development globally. The UK was one of the first jurisdictions to introduce a legal requirement concerning transparency in supply...more
9/19/2024
/ Anti-Corruption ,
Disclosure Requirements ,
Environmental Social & Governance (ESG) ,
Human Rights ,
Human Trafficking ,
International Trade ,
Modern Slavery Act ,
Reporting Requirements ,
Supply Chain ,
Transparency ,
UK ,
White Collar Crimes
The UK government introduced a major overhaul of its framework for addressing financial crime — and brought into force numerous significant changes — when the Economic Crime and Corporate Transparency Act 2023 (the Act)...more
9/12/2024
/ Anti-Corruption ,
Anti-Money Laundering ,
Corporate Crimes ,
Corporate Entities ,
Corporate Governance ,
Corporate Transparency Act ,
Enforcement Actions ,
EU ,
Failure to Prevent ,
Financial Crimes ,
Fraud ,
Strict Liability ,
UK ,
White Collar Crimes
On 31 July 2024, the UK government broadened its Russian sanctions regime, giving the government express power to impose sanctions on persons who provide financial services, or make available funds, economic resources, goods...more
Russia’s invasion of Ukraine has resulted in unprecedent judicial scrutiny of the UK’s sanctions regulations. While the judgments delivered in many cases have provided companies with needed certainty on some topics, the...more
In Nuctech Warsaw (T-284/24), the EU Court of Justice held that EU subsidiaries can lawfully be required to provide access to email accounts and data held by their overseas parent company. The ruling involved the following...more
8/26/2024
/ Appeals ,
Commercial Litigation ,
Corporate Counsel ,
Corporate Governance ,
Enforcement Actions ,
EU ,
European Commission ,
European Court of Justice (ECJ) ,
Extraterritoriality Rules ,
Foreign Corporations ,
Popular ,
Privacy Laws ,
UK ,
White Collar Crimes
The UK Court of Appeal recently held that the National Crime Agency’s decision not to investigate whether cotton goods manufactured in China and imported to the UK were the product of forced labour was unlawful — a decision...more
7/8/2024
/ Appeals ,
China ,
Corporate Counsel ,
Financial Crimes ,
Financial Institutions ,
Imports ,
International Trade ,
Legislative Agendas ,
National Crime Agency (NCA) ,
Popular ,
Proceeds of Crime Act 2002 (POCA) ,
Supply Chain ,
UK
Historically, multinational companies and those lobbying on their behalf mostly concerned themselves with the U.S. and Canadian legal frameworks for lobbying. But more and more jurisdictions are establishing increasingly...more
Below is a summary of recent developments and enforcement trends in the UK white collar crime space in the first quarter of 2024.
I. New Legislation -
The Economic Crime and Corporate Transparency Act 2023 (ECCTA)...more
On March 26, 2024, the French Anti-Corruption Agency (AFA) published a guide on how to engage in corporate sponsorship and charitable donation activities while appropriately mitigating corruption risks (the Guide)...more
5/13/2024
/ AFA ,
Anti-Corruption ,
Charitable Donations ,
Cooperation ,
Corporate Misconduct ,
Criminal Prosecution ,
EU ,
France ,
Internal Investigations ,
New Guidance ,
Self-Reporting ,
Sponsorship Agreements ,
UK ,
White Collar Crimes
On 22 February 2024, shortly before the second anniversary of Russia’s invasion of Ukraine, the UK government published its first sanctions strategy (the Strategy). The Strategy explains the UK’s use and implementation of...more
3/12/2024
/ Belarus ,
Economic Sanctions ,
EU ,
Foreign Policy ,
International Trade ,
Licensing Rules ,
Office of Financial Sanctions Implementation (OFSI) ,
Reporting Requirements ,
Russia ,
Sanctions ,
UK ,
Ukraine
On 26 October 2023, the Economic Crime and Corporate Transparency Act 2023 (the Act) became law in the UK. The Act represents a major overhaul of the UK government’s framework for tackling financial crime and has brought into...more
2/26/2024
/ Anti-Corruption ,
Anti-Money Laundering ,
Corporate Crimes ,
Corporate Governance ,
Corporate Transparency Act ,
Cryptocurrency ,
Digital Assets ,
Enforcement Actions ,
EU ,
Financial Crimes ,
Investigations ,
Regulatory Agenda ,
UK ,
White Collar Crimes
With Russia’s invasion of Ukraine nearing the end of its second year, the United Kingdom has continued to introduce sanctions measures against Russia, with the latest round announced on 14 December 2023....more
1/22/2024
/ Economic Sanctions ,
EU ,
Financial Institutions ,
General Licenses ,
Oil & Gas ,
Oil Prices ,
Reporting Requirements ,
Russia ,
Sanctions ,
Trade Restrictions ,
UK ,
Ukraine
DOJ Increases Resources To Investigate and Prosecute Sanctions Evasion and Export Control Violations -
On March 2, 2023, during a keynote speech at the American Bar Association’s annual White Collar Crime National...more
3/17/2023
/ Anti-Corruption ,
Bureau of Industry and Security (BIS) ,
Compliance ,
Corporate Entities ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Economic Sanctions ,
EU ,
Export Controls ,
Exports ,
Financial Institutions ,
Foreign Corrupt Practices Act (FCPA) ,
International Trade ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Self-Disclosure Requirements ,
U.S. Commerce Department ,
U.S. Treasury ,
UK ,
Voluntary Disclosure
On January 16, 2023, France’s financial prosecutor, the “Parquet National Financier” (PNF), issued updated guidance (the Guidelines) regarding its approach to offering, negotiating and entering into French deferred...more
2/6/2023
/ Anti-Corruption ,
Anti-Money Laundering ,
Attorney-Client Privilege ,
CJIP ,
Compensation ,
Corporate Crimes ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement ,
France ,
Guidance Update ,
Public Statements ,
Reporting Requirements ,
UK ,
White Collar Crimes