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
On 28 February 2024, a statutory instrument (SI) – the Russia (Sanctions) (EU Exit) (Amendment) (Regulations) 2024 – was published on legislation.gov.uk. The SI amends the Russia (Sanctions) (EU Exit) Regulations 2019.
The SI was published alongside an explanatory memorandum, which notes that the legislation will ban the import of Russian diamonds
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:
Introduction
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
Introduction
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
On 6 October 2023, the English Court of Appeal (Court of Appeal) handed down its judgment in Mints v PJSC National Bank Trust [2023] EWCA Civ 1132. The judgment considered the English High Court’s decision in PJSC National Bank Trust and another v Boris Mints and others [2023] EWHC 118 (Comm)
On 6 September 2023, the UK Financial Conduct Authority (the FCA) published the findings of its review of the sanctions systems and controls in place at over 90 financial services firms operating in a range of sectors (the Review).
This briefing summarises the FCA’s findings on good practices currently being followed by firms