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As the FinTech industry continues to experience increased regulation across multiple jurisdictions, the focus of sanctions authorities is turning to decentralised finance (DeFi) and those operating in the crypto space. In the US we have seen a wave of recent enforcement actions against participants in the crypto sector and strong statements from authorities

In March 2022, a year after Russia’s invasion of Ukraine, the Treasury Committee published a report regarding the development, implementation and impact of economic sanctions on Russia (the 2022 Report).  In brief, the 2022 Report found that:

  • Despite its own production of
  • The UK’s Industry and Economic Security Minister, Nusrat Ghani, today announced the creation of a new civil enforcement unit, the Office of Trade Sanctions Implementation (OTSI). OTSI is expected to become operational early next year, and will focus on the civil enforcement of trade sanctions, including in relation to the circumvention or evasion


    As anticipated in our previous horizon scan (see here), the end of 2023 has brought about significant developments in financial crime enforcement and a real focus on fraud. Looking ahead to 2024, we predict that developments affecting organisations doing business in the UK will include:

    1. a focus from organisations on fraud, in particular


    Following the unprecedented levels of sanctions activity in response to Russia’s invasion of Ukraine, which has resulted in companies dealing with the most significant and complex sanctions regimes across multiple jurisdictions, authorities in the US, UK and EU are now turning their attention to enforcement of those sanctions.

    Sanctions authorities have indicated that they