Steptoe & Johnson LLP (LexBlog United Kingdom)

On October 8, 2023, highly anticipated regulatory changes came into effect bringing qualifying cryptoassets within the scope of the UK’s existing financial promotions regime and the remit of the Financial Conduct Authority (“FCA”).  The regulatory changes effectively ban unauthorized firms globally from marketing qualifying cryptoassets to UK consumers, which are now deemed as “controlled...

On September 8, 2023, the UK Departments for Business and Trade and International Trade jointly published guidance on the scope of the sanctions on certain Russian iron and steel products processed in a third country that will come into effect under Part 5, Chapter 4CA of The Russia (Sanctions) (EU Exit) Regulations 2019 (“Russia Regulations”)...

On September 6, 2023, the Financial Conduct Authority (“FCA”), the UK regulator for financial services firms and markets, published a review of its assessment of sanctions systems and controls in place at financial services firms in the UK.  The review sought, in particular, to assess firms’ response to the rapid expansion in the size, scale,...

On August 18, 2023, the UK High Court issued a judgment in the first sanctions designation challenge pursuant to the UK’s Russia sanctions regime under Section 38 of the Sanctions and Anti-Money Laundering Act 2018 (“SAMLA”).  The challenge was brought by Eugene Shvidler (“Mr. Shvidler”), a UK-US dual national businessman, following an unsuccessful ministerial review in which...

On September 1, 2023, the Financial Conduct Authority (“FCA”) set out its expectations for cryptoasset businesses in the UK’s compliance with the “Travel Rule”, introduced by The Money Laundering and Terrorist Financing (Amendment) (No. 2) Regulations 2022 (the “Amended MLRs”).  The Travel Rule requires cryptoasset businesses to gather, authenticate, and share information concerning cryptoasset...

GDPR Enforcement Trends provides a monthly summary on enforcement action taken by data protection authorities within the UK and EU under the General Data Protection Regulation. We provide key takeaways from the previous month’s developments and identify the EU’s most active regulators. Click below to download a PDF version of the tracker.

On August 31, 2023, OFSI made its first use of the disclosure enforcement power granted to it pursuant to the Economic Crime (Transparency and Enforcement) Act 2022 (“ECA”) in relation to a case involving Wise Payments Limited (“Wise”) making funds available to a company owned or controlled by a UK designated person contrary to the...

Earlier this year, the European Union (EU) voted in favour of the Markets in Crypto-Assets (“MiCA”) bill, which aims to regulate the crypto industry within the EU. The bill is seen as a major step towards establishing a comprehensive regulatory framework for cryptocurrencies and other digital assets in the EU that will undoubtedly make the...

GDPR Enforcement Trends provides a monthly summary on enforcement action taken by data protection authorities within the UK and EU under the General Data Protection Regulation. We provide key takeaways from the previous month’s developments and identify the EU’s most active regulators. Click below to download a PDF of this month’s update.

On June 15, 2023, the UK Government announced proposals to introduce the biggest reform of corporate crime legislation in more than 50 years, with the result that, if enacted into law, companies who commit fraud, money laundering and bribery will be subject to greater scrutiny and be at greater risk of being successfully prosecuted. The...

On June 8, 2023, The Republic of Belarus (Sanctions) (EU Exit) (Amendment) Regulations 2023 (“Regulations”) were laid before parliament.  The Regulations significantly expand the UK’s package of sanctions targeting Belarus in response to the continued facilitation of Russia’s invasion of Ukraine by the Belarusian regime.  The new measures expand the criteria pursuant to which persons...

GDPR Enforcement Trends provides a monthly summary on enforcement action taken by data protection authorities within the UK and EU under the General Data Protection Regulation. We provide key takeaways from the previous month’s developments and identify the EU’s most active regulators. Click below to download a PDF of this month’s update.

On May 22, 2023, the Department for Business and Trade’s Export Control Joint Unit published new guidance on trade sanctions circumvention under the UK’s Russia sanctions regime (the “Guidance”).  While direct trade between the UK and Russia reportedly has fallen significantly since the introduction of a broad package of trade sanctions in response to Russia’s...

GDPR Enforcement Trends provides a monthly summary on enforcement action taken by data protection authorities within the UK and EU under the General Data Protection Regulation. We provide key takeaways from the previous month’s developments and identify the EU’s most active regulators. Click below to download a PDF of this month’s update.

In our alert called “Criminal Investigations in the UK: What to Watch for the UK and the EU in 2023”, we predicted the introduction of a new “failure to prevent” offence. We predicted that such a new offence would likely have far-reaching, and potentially seismic, consequences on organizations both (i) in having to ensure that...

GDPR Enforcement Trends provides a monthly summary on enforcement action taken by data protection authorities within the UK and EU under the General Data Protection Regulation. We provide key takeaways from the previous month’s developments and identify the EU’s most active regulators. Click below to download a PDF of this month’s update.

On March 21, 2023, HM Treasury’s Office of Financial Sanctions Implementation (“OFSI”) designated all individuals and entities that currently are subject to an asset freeze under the Russia (Sanctions) (EU Exit) Regulations 2019 (the “Regulations”) for the additional purpose of the trust services sanctions measures outlined in Regulation 18C(1) of the Regulations.  As a result, persons...

On March 14, 2023, the UK High Court issued a judgment in the first challenge to a UK sanctions listing under Section 38 of the Sanctions and Anti-Money Laundering Act 2018 (“SAMLA”).  The challenge was brought by LLC Synesis, a Belarusian technology company (“Synesis”) and followed an unsuccessful ministerial review of Synesis’ UK designation.  The...

GDPR Enforcement Trends provides a monthly summary on enforcement action taken by data protection authorities within the UK and EU under the General Data Protection Regulation. We provide key takeaways from the previous month’s developments and identify the EU’s most active regulators. Click below to download a PDF of this month’s update.

On March 1 and 7, 2023, the National Security Bill (the “Bill”) will enter the Report stage of the House of Lords, during which members of the House of Lords will be given a further opportunity to examine and make amendments to the Bill. The Bill was first introduced by the Home Secretary on May...

On February 9, 2023, the UK announced the designation of seven individuals said to be part of a Russia-based cybercrime gang under the UK’s thematic cyber sanctions regime pursuant to The Cyber (Sanctions) (EU Exit) Regulations 2020.  The designations were coordinated with the US.  Concurrently, HM Treasury’s Office of Financial Sanctions Implementation (“OFSI”), in partnership...

On February 7, 2023, the UK Department for International Trade (“DIT”) published an expanded version of its guidance on supplying professional and business services to a person connected with Russia (“DIT Guidance”), following a broadening of the types of services covered by the ban in December 2022.  The DIT Guidance sets out additional details regarding...

On 8 February 2023, the U.K. Government confirmed its intention to propose that a new “failure to prevent” corporate criminal offence be included in the Economic Crime Bill, along similar lines to the “failure to prevent bribery” offence under section 7 of the Bribery Act 2010 (the “Bribery Act”) and the two “failure to prevent...

On February 5, 2023, the UK ban imposed by Part 5, Chapter 4IA of The Russia (Sanctions) (EU Exit) Regulations 2019, as amended (“Russia Regulations”), on the maritime transportation of certain Russian oil products and related services came into effect.  Ahead of the measure coming into force, on February 4, 2023, HM Treasury’s Office of...

On December 15, 2022, The Russia (Sanctions) (EU Exit) (Amendment) (No. 17) Regulations 2022 (“Amendment 17”) were laid before parliament.  Amendment 17 revises existing restrictions on dealing with securities, money market instruments, loans and credit to prohibit new investments in Russia via third countries.  It also introduces a new prohibition on the provision of trust...

On November 21, 2022, the UK Department for Business, Energy and Industrial Strategy published guidance on the UK ban on Russian oil and oil products intended for entry into the UK (the “BEIS Guidance”) that was legislated for by the Russia (Sanctions) (EU Exit) (Amendment) (No. 14) Regulations 2022 and will come into effect on...

On November 14, 2022, HM Treasury’s Office of Financial Sanctions Implementation (“OFSI”) published detailed guidance on the recently published ban on the provision of maritime transportation of Russian oil and oil products and related services (“OFSI Guidance”).  The OFSI Guidance sets out additional details regarding how the oil price cap exception will operate as well...

On November 3, 2022, a sixteenth amendment to the UK’s Russia sanctions regime was laid before parliament.  The Russia (Sanctions) (EU Exit) (Amendment) (No. 16) Regulations 2022 (“Amendment 16”) introduces a ban on UK ships and services such as insurance, brokerage and shipping facilitating the maritime transport of Russian crude oil from December 5, 2022. ...

On October 28, 2022, further amendments to the UK’s Russia sanctions regime were laid before parliament.  The new measures introduced under the Russia (Sanctions) (EU Exit) (Amendment) (No. 15) Regulations 2022 (“Amendment 15”) include an expansion of the ban on loan and credit arrangements and the items covered by existing trade restrictions on oil refining,...

On September 30, 2022, the UK Foreign Secretary, James Cleverly, announced new services and goods export bans targeting vulnerable sectors of the Russian economy in response to President Putin’s announcement of the annexation of the Ukrainian regions of Donetsk, Luhansk, Kherson and Zaporizhzhia following sham referendums.  The imposition of an asset freeze also was announced...