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Economic Sanctions › Control Test

King & Spalding

Recent OFAC and DOJ Activity Signals Potential New Era of Control-Based Sanctions Enforcement

King & Spalding on

U.S. sanctions enforcement is evolving to adopt a “control” analysis similar to the analysis employed by the European Union and United Kingdom based on a recent major enforcement action by the U.S. Department of the...more

Skadden, Arps, Slate, Meagher & Flom LLP

‘Control’ Under the UK’s Sanctions: The Emergence of Clarity?

Skadden, Arps, Slate, Meagher & Flom LLP on

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

WilmerHale

Court Judgment Regarding Scope of the Ownership and Control Test Under the UK Sanctions Regime

WilmerHale on

On Friday, 6 October 2023 the Court of Appeal handed down judgment in the case of Mints v PJSC National Bank Trust & Anr [2023] EWCA Civ 1132. This judgment is significant and is a key, albeit non-binding, indicator of the UK...more

WilmerHale

OFSI Issues Updated Guidance Relating to Assessments of due Diligence Conducted in Relation to the “Ownership and Control” Test,...

WilmerHale on

The Office of Financial Sanctions Implementation (OFSI) has updated its ‘enforcement and monetary penalties for breaches of financial sanctions’ guidance, which was last updated in June 2022. ...more

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