Sanctions
Economic sanctions are a complex, high-risk and ever-changing mix of law, economics, policy and international relations.
Business Crime - Sanctions publications
Post-Mints: to what extent does Vladimir Putin “control” everything in Russia?
23 november 2023
Over a month since the Court of Appeal's judgment in PJSC National Bank Trust and another v Boris Mints and others, the Foreign, Commonwealth and Development Office (“FCDO”) and the Office of Financial Sanctions Implementation (“OFSI”) have now issued updated guidance on interpreting the "control" test in the Russia (Sanctions) (EU Exit) Regulations 2019 (the "Russia Regulations"). The case has also been considered by the High Court in Litasco SA v Der Mond Oil and Gas Africa SA and another. This post will consider these post-Mints developments and what they mean for interpreting the Russian regulations.
GIR Guide to Sanctions 4th edition: Key Sanctions Issues in Civil Litigation and Arbitration
20 oktober 2023
The GIR Guide to Sanctions 4th edition – Key Sanctions Issues in Civil Litigation and Arbitration is a comprehensive resource that helps practitioners navigate the increasingly complex world of sanctions. The guide addresses the impact of sanctions on contractual relationships, civil litigation, and arbitration, offering insights on various regimes and practical challenges they pose for businesses and their advisers.
Mints case ruling: UK sanctions do not prevent designated persons from accessing UK courts and receiving judgments
17 oktober 2023
Read our analysis of the Court of Appeal’s ruling in Boris Mints & Ors v PJSC National Bank Trust & Anor, including the implication of the obiter remarks.
Responses to the Russia/Ukraine Crisis – Sanctions Update No. 6
2 mars 2023
It is now over a year since Russia first invaded Ukrainian territory and countries in the West and beyond began imposing tough new financial and other sanctions on the Russian regime and its supporters. In recent months it has been the reduction of, and in some cases, outright ban on, the importation of oil and gas that has been the most serious and impactful action taken by the G7 and allied countries.
In this update to our earlier articles in this series, we look at the major recent developments in the UK, EU and U.S. sanctions programmes and consider their impact.
Responses to the Russia/Ukraine Crisis - Sanctions Update No. 5
26 oktober 2022
The purported annexation by Russia of four Ukrainian oblasts was met with condemnation by the United Nations and the announcement of a new round of sanctions on Russian entities, individuals and goods by many countries, including the UK, EU and U.S. Acting together, the G7 states also have agreed to cap the price they will pay for Russian-origin crude oil and petroleum products in an effort to reduce the income Russia is receiving for its oil.
In our fifth update we look at recent major developments in the UK, EU and U.S. sanctions programmes and consider their impact.
UK Sanctions reporting: Cryptoasset exchange and custodian wallet providers now subject to enhanced sanctions reporting requirements; firms’ annual frozen assets reports due soon
7 september 2022
Reporting requirements under UK sanctions regimes, including those of Russia and Belarus, have been extended recently to include cryptoasset exchange providers and custodian wallet providers. These businesses must now comply with enhanced sanctions reporting obligations under the Regulations. Meanwhile, OFSI has just sent out its annual request to all UK businesses for sanctions information - and the deadline is fast approaching.
UK Government provides details on Russian oil shipping ban and price cap
22 september 2022
In a recent sanctions briefing to the business sector, the UK Government provided further details on anticipated measures to implement the ban on maritime services and Russian oil price cap announced by G7 Ministers earlier this month.
Six months on – Changes to international business since Russia’s invasion of Ukraine
23 augusti 2022
It is unlikely that, when Russia invaded Ukraine six months ago, international companies would have anticipated the extent to which their own economic and commercial activities would be affected by the political reaction to the crisis. Global responses to the war have elevated geo-political tensions and stringent economic sanctions have had a dramatic impact on a number of key sectors and industries.
In this article we look at how “business as usual” has changed in the six months since the crisis began, focusing on energy, finance and consumer business.
Responses to the Russia/Ukraine Crisis – Sanctions Update No. 4
3 augusti 2022
The crisis in Ukraine is showing no signs of abating and governments across the globe are ramping up their sanctions and designations. With financial markets already subject to stringent restrictions, attention has focussed on expanding trade and services sanctions. There is now virtually no economic or business sector which is not affected in some way by the impact of international restrictions.
Responses to the Russia/Ukraine Crisis – Sanctions Update No.3
12 juni 2022
It is now over 100 days since Russian military action began in Ukraine, during which time Western governments and their allies have imposed raft after raft of economic and trade restrictions on Russian-owned companies, banks, industries and the individuals supporting the Kremlin. In our third update on sanctions developments across the UK, U.S. and Europe we track the most recently imposed restrictions and look ahead at what may yet be introduced.
Responses to the Russia/Ukraine Crisis - Sanctions Update No. 2
29 april 2022
Despite global calls for Russia to cease its aggressive activities, the crisis in Ukraine is showing no sign of ending any time soon. The UK, EU, U.S. and other countries have been ratcheting up their responses and imposing a succession of sanctions and restrictions on the Russian financial and trade sectors, as well as targeting individuals, including politicians, oligarchs and others connected to the Government of Russia.
In this update to our article of 3 March 2022, we look at the major sanctions developments in the UK, EU and U.S. since then and consider their impact.
The UK strengthens its response to money laundering and corruption with the Economic Crime (Transparency and Enforcement) Act 2022
22 mars 2022
After passing through Parliament in double-quick time, the Economic Crime (Transparency and Enforcement) Act 2022 received Royal Assent on 15 March 2022. While the Act’s introduction has been hastened by the Russian invasion of Ukraine, it is part of the UK government’s continuing push to increase transparency in financial dealings and tackle corruption more widely.
The Russia/Ukraine Crisis - Sanctions Update
3 mars 2022
As the conflict in Ukraine has developed, so has the package of sanctions imposed by governments across the world on Russian entities and individuals. The need to stay on top of the legal situation across jurisdictions is critical, particularly for businesses with international operations involving parties that may now be subject to economic restrictions. However, the situation is constantly changing and not all sanctions regimes are moving in parallel.
In this briefing we set out the current position in the UK, EU and U.S., with some background as to how we got here.
The long arm of sanctions indictments
1 mars 2022
The General Court of the European Union dismissed an application by Pilatus Bank plc to annul a decision of the European Central Bank which withdrew Pilatus Bank's banking licence. The Court held that the ECB could withdraw Pilatus Bank's authorisation on the basis of the “good repute” of its shareholder who had been arrested in the United States on charges of breaching US sanctions. Banks and other financial institutions should note the direction of travel set by the ECB, particularly in light of the recent raft of new sanctions against Russia.
