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What have the financial services regulators been doing following the sanctions imposed on Russia?

In the latest instalment of our Regulation Around the World series we cover some of the regulatory alerts that financial services regulators have issued in key jurisdictions.

Our global updater focussing on the regulatory alerts is accompanied by further analysis in

On 28 May 2020, Flex Ltd (“Flex”), a Singapore-based electronics manufacturer listed on the NASDAQ, disclosed in its 2020 US Securities and Exchange Commission (“SEC”) filing that it had initiated a voluntary self-disclosure to the US Office of Foreign Assets Control (“OFAC”) on 14 February 2019. The initial disclosure related to possible non-compliance with US

On 14 May 2020, following engagement with the private sector, including UK based insurers, the U.S. Government issued new sanctions guidance for international maritime operators.  The intent of the guidance is to provide those in the maritime industry, energy and metals sectors with further information and tools to counter current and emerging trends related to

Yesterday, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) published ‘A Framework for OFAC Compliance Commitments’* in order to provide organizations subject to US jurisdiction, as well as foreign entities that conduct business in or with the United States or US persons, or that use US-origin goods or services, with a framework on the essential components of a sanctions compliance program (SCP). The document* also outlines how OFAC may incorporate these components into its assessment of apparent violations and resolution of investigations resulting in settlements. OFAC strongly encourages organizations to approach sanctions compliance using a risk-based analysis by developing and updating a SCP.

Over the last few months, US economic sanctions have taken the front pages as the Trump Administration has reinstated certain sanctions aimed at Iran following the United States withdrawal from the Joint Comprehensive Plan of Action (“JCPOA”). While the so-called “snapback” reinstated sanctions provisions increase the risk for non-US companies, recent enforcement actions against non-US companies demonstrate that such companies have always been at risk of violating the US sanctions laws.