Sanctions

On 21 December 2023, the European Banking Authority (EBA) issued a public consultation on two sets of guidelines on internal policies, procedures and controls to ensure the implementation of EU and national restrictive measures.

One set of draft guidelines is addressed to financial institutions and prudential supervisors and sets common, regulatory expectations regarding

On 2 December 2022, HM Treasury published updated statutory guidance to assist in the implementation of, and compliance with the Russia (Sanctions) (EU Exit) Regulations 2019. The guidance has been updated to clarify the application of the prohibition on provision of technical assistance, financial services or funds related to G7 dependency and further goods.

On 4 May 2022, the UK Government announced a ban on services exports to Russia, and as of 21 July 2022 that ban is now in force by virtue of regulation 54C of The Russia (Sanctions) (EU Exit) Regulations 2019 (as amended by The Russia (Sanctions) (EU Exit) (Amendment) (No. 14) Regulations 2022) (the Regulations

The Economic Crime (Transparency and Enforcement) Act 2022 (the Act), which came into force in March 2022, aimed amongst other things, to give UK sanctions authorities greater power to take enforcement action and impose penalties on persons that breach sanctions restrictions, through the introduction of a “strict liability” test. These new powers of the UK’s

On 11 July 2022, there was published a letter by the Financial Conduct Authority (FCA) to the House of Commons’ Treasury Committee regarding the regulator’s financial sanctions responsibilities.

In the letter, the FCA addresses its responsibilities for financial sanctions and covers the following topics:

  • The current level of awareness and compliance at authorised firms of

On 6 July 2022, the FCA published Policy Statement 22/8 ‘Protecting investors in authorised funds following the Russian invasion of Ukraine’ (PS22/8).

In PS22/8 the FCA responds to feedback to Consultation Paper 22/8 (CP22/8) and sets out final rules and guidance which allow authorised fund managers to create separate unit classes (side pockets) for retail

On 28 April 2022, the Financial Conduct Authority (FCA) published Consultation Paper 22/08: Protecting investors in authorised funds following the Russian invasion of Ukraine (CP22/08).

The FCA has published CP22/08 in light of the significant impact that Russia’s invasion of Ukraine is having on financial markets. Many investments have been affected both by the events