Crowell & Moring LLP (LexBlog United Kingdom)

On this 4thof July, Britain was also celebrating. The first country to secure a trade deal with the Trump Administration, the U.K. can indeed celebrate the so-called Special Relationship. But what exactly is in the deal? For starters it’s not a free trade agreement in the traditional sense. Rather, it’s more like a starter pack,...

In November 2024, the UK Government introduced regulations which granted its financial sanctions regulator – the Office of Financial Sanctions Implementation (“OFSI”) – greater intelligence gathering and enforcement powers. Our previous blog post on these amendments can be found here. The changes included the extension of mandatory financial sanctions reporting obligations (“UK Reporting Regime”)

In a move to strengthen its sanctions regime against Russia, the UK introduced additional sanctions through the publication of The Russia (Sanctions) (EU Exit) (Amendment) Regulations 2025. The new sanctions came into force on April 24, 2025. Key Points of Note: In parallel, the UK Government has published new guidance on complying with the new...

The UK’s Office of Financial Sanctions Implementation (“OFSI”) has imposed a monetary penalty of £465,000 against a multinational law firm’s Russian office (the “Russian Office”) for breaching UK financial sanctions against Russia following its invasion of Ukraine in February 2022.  This is the first time OFSI has enforced against a law firm. The Russian Office...

As they have on each previous anniversary, the EU and UK released new sanctions against Russia on February 24, 2025, to mark the three-year anniversary of Russia’s full-scale invasion of Ukraine. For the first time, the United States did not do the same, electing to issue a limited set of Iran-related sanctions on the anniversary...

The Information Sharing (Disclosure by the Registrar) Regulations 2024 (the “Regulations“) came into force in December 2024. The Regulations enhance insolvency practitioners (including the Official Receiver) (“IPs“) powers of investigation by providing them with greater access to information held by Companies House. Previous Regime Before the Regulations came into force, Companies House had...

To kick-start 2025, the UK’s recently established Office of Trade Sanctions Implementation (“OTSI”) has published two related guidance notes for UK exporters on Russian trade sanctions evasion and diversion. First, Countering Russian sanctions evasion – guidance for exporters seeks to support UK exporters and manufacturers in identifying Russian evasion practices and mitigating the risk of...

The UK Government has passed new amending sanctions regulations which grants its financial sanctions regulator – the Office of Financial Sanctions Implementation (“OFSI”) – greater intelligence gathering and enforcement powers, and enables OFSI to deal with licensing applications more efficiently.    The majority of the amendments introduced by The Sanctions (EU Exit) (Miscellaneous Amendments) (N

From Thursday October 10, 2024, the UK has an additional new sanctions regulator following the official launch of the Office of Trade Sanctions Implementation (“OTSI”).  First announced in December 2023, its establishment was confirmed last month with the publication of The Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 (the “Regulations).  Sitting within the...

With news of serious forced labour allegations emerging in the UK, calls for forced labour reforms will require companies to take proactive action to monitor and mitigate risk. Click here to continue reading the full version of this alert.

On August 20, 2024, the Department of State’s Directorate of Defense Trade Controls (DDTC) published an interim final rule to streamline defense trade between and among Australia, the United Kingdom (UK), and the United States in furtherance of the trilateral security partnership (the “AUKUS” partnership). The interim final rule implements the proposed rule DDTC published on May...

On August 20, 2024, the Department of State’s Directorate of Defense Trade Controls (DDTC) published an interim final rule to streamline defense trade between and among Australia, the United Kingdom (UK), and the United States in furtherance of the trilateral security partnership (the “AUKUS” partnership). The interim final rule implements the proposed rule DDTC published...

An overview on new Russian sanctions and export controls issued by the U.S. (OFAC and BIS) and the UK focusing on the Russian financial, military, and LNG industries. Click here to continue reading the full version of this alert.

On May 1, 2024, the Department of State’s Directorate of Defense Trade Controls (DDTC) published a proposed rule that, if implemented, would streamline defense trade between and among Australia, the United Kingdom (UK), and the United States in furtherance of the trilateral security partnership (the “AUKUS” partnership). DDTC issued the proposed rule pursuant to new authorities and...

On May 1, 2024, the UK’s financial sanctions regulator – the Office of Financial Sanctions Implementation (“OFSI”) – launched a new Frequently Asked Quesstion service, setting out consolidated responses to frequently asked questions about UK financial sanctions.  Russia is the key focus, with FAQs dedicated to the UK’s asset freezing sanctions, other financial prohibitions, and...

On May 1, 2024, the Department of State’s Directorate of Defense Trade Controls (DDTC) published a proposed rule that, if implemented, would streamline defense trade between and among Australia, the United Kingdom (UK), and the United States in furtherance of the trilateral security partnership (the “AUKUS” partnership).  Click here to continue reading the full version...

Europe’s biggest online fashion retailer, Zalando, recently agreed to dramatically and rapidly overhaul its sustainability marketing in the face of pressure by the European Commission. This is yet another example of why companies need to be extremely careful when making environmental claims in their advertising. Such claims are facing increasing regulatory scrutiny and activist litigation in the..

Jan. 25, 2024—The United Kingdom (“UK”)-based Anti-Slavery International, in combination with the Investor Alliance for Human Rights and the Helena Kennedy Centre for International Justice at Sheffield Hallam University, has published a series of reports addressing the issue of forced labor in solar and electric vehicle supply chains relating to Uyghur and other Turkic ethnic...

From September 30, 2023, new EU and UK sanctions will come into effect targeting the imports of specified iron and steel products which are processed in third countries and incorporate Russian-origin iron and steel inputs. Importers will need to declare upon import whether the imported goods are compliant (and be prepared to provide evidence demonstrating...

From September 30, 2023, new EU and UK sanctions will come into effect targeting the imports of specified iron and steel products which are processed in third countries and incorporate Russian-origin iron and steel inputs. Importers will need to declare upon import whether the imported goods are compliant (and be prepared to provide evidence demonstrating...

From September 30, 2023, new EU and UK sanctions will come into effect targeting the imports of specified iron and steel products which are processed in third countries and incorporate Russian-origin iron and steel inputs. Importers will need to declare upon import whether the imported goods are compliant (and be prepared to provide evidence demonstrating...

On July 10, 2023, the State Department released a Fact Sheet with additional details on the AUKUS Trade Authorization Mechanism (ATAM). ATAM appears likely to operate as a license exemption under the International Traffic in Arms Regulations (ITAR), leveraging the existing ITAR §126.4, to authorize transfers of certain approved categories of defense articles and services...

UK Releases General License Permitting Agricultural Commodities Exports: On November 4, 2022, the UK’s Office of Financial Sanctions Implementation (“OFSI”) issued a new general license under its Russia sanctions regime. This license permits exporters of agricultural commodities and UK Department of International Trade License holders: (1) to receive funds and economic resources from any person,..

New U.S. and UK Sanctions Partnership: On October 13, 2022, the Office of Foreign Assets Control (“OFAC”) and the UK’s Office of Financial Sanctions Implementation (“OFSI”) announced that they had concluded multi-day meetings in London involving technical exchange of information between the two sanctions authorities.  The agencies have decided to enhance OFAC-OFSI cooperation further, including...

New U.S., UK, and EU Designations: On September 30, 2022, the U.S. designated 295 individuals and entities.  The new designations included 14 persons in Russia’s military industrial complex, including Sinno Electronics Co. and Taco LLC, Chinese and Armenian suppliers, for their support of a Russian defense procurement firm.  The U.S. also targeted two Russian financial...

UK Designates 89 Individuals and Three Entities: On September 26, 2022, in response to Russia’s “sham” referendums to annex four Russian-occupied regions in Ukraine, the UK designated an additional 92 individuals and entities.  “Today’s sanctions will target those behind these sham votes, as well as the individuals that continue to prop up the Russian regime’s...

The UK has seen the launch of a competition-law based collective action – the equivalent of a class action in other countries – on behalf of an estimated 240,000 investors in the digital assets space.  The claim is brought against four cryptocurrency exchanges: Binance, Bittylicious, Kraken and ShapeShift.  It alleges that those exchanges colluded in...

UK Sanctions Removal and Other Amendments: On August 23, 2022, the UK delisted Mikhail Vladimirovich Razvozhayev, the Governor of Sevastopol, who had been subject to a UK asset freeze since late July 2022.  The UK published amendments for 42 other individuals and entities, primarily revising descriptions of the parties. U.S. and UK Issue General Licenses:...

UK Publishes General License for Energy for Mongolia: On August 16, 2022, the UK published General License INT/2022/2085212 for Mongolia energy payments.  The license permits payments to the Credit Bank of Moscow, Gazprombank, Sberbank, Rosbank PJSC, or any entity owned or controlled by these banks, for the purpose of making energy available for use in...

New UK Sanctions:On July 21, 2022, the UK introduced a new tranche of restrictions in the 14th amendment to its Russian Sanctions Regulations.  Several of the new restrictions are detailed below. The UK prohibited UK persons from directly or indirectly providing accounting services, business and management consulting services, and public relations services to “persons connected...