Steptoe & Johnson LLP (LexBlog United Kingdom)

On April 2, 2024, HM Treasury’s Office of Financial Sanctions Implementation (“OFSI”) published a blog post addressing financial sanctions compliance in the maritime sector.  Maritime businesses currently are a particular area of focus for UK sanctions regulators and law enforcement due to the direct and multi-faceted impact of the UK’s Russia financial, trade, and transport...

On February 27, 2024, HM Treasury’s Office of Financial Sanctions Implementation (“OFSI”) published a number of guidance documents on financial sanctions licensing addressing the process of applying for a licence, as well as the principles applied when making licensing decisions relating to designated individuals.  Publication of the guidance follows a recent court case in which...

The UK’s National Economic Crime Centre (“NECC”) recently issued an amber alert concerning the sanctions evasion, money laundering, and trafficking in cultural property risks presented to UK industries linked to artwork storage facilities and the art storage sector (the “Amber Alert”).  The Amber Alert highlights that criminals are finding ways to utilize the art market...

On December 11, 2023, the UK’s Department for Business & Trade (“DBT”) published a General Trade Licence of indefinite duration concerning measures related to third-country processed iron and steel, pursuant to The Russia (Sanctions) (EU Exit) Regulations 2019 (the “Russia Regulations”) (the “GL”).  The GL has been introduced to provide additional clarity in key areas...

On December 14, 2023, the UK government issued new Russia sanctions legislation under The Russia (Sanctions) (EU Exit) (Amendment) (No.4) Regulations 2023 (“Amendment No. 4”) and The Russia (Sanctions) (EU Exit) (Amendment) (No.5) Regulations 2023 (“Amendment No. 5”).  The new sanctions make good on commitments made by the United Kingdom as part of the G7...

On December 6, 2023, the UK’s National Economic Crime Centre (“NECC”) issued a red alert concerning the export of high-risk goods that Russia is using on the battlefield in Ukraine.  The red alert outlines sanctions evasion red flags for the financial services, transportation, and logistics sectors, including features of suspicious transactions, customers, requested services, and...

On October 30, 2023, HM Treasury released a policy update announcing its intention to bring forward secondary legislation to introduce regulatory measures for specific cryptoassets known as stablecoins by early 2024.  The policy update outlines the proposed framework for regulating the issuance, custody, and utilization of fiat-backed stablecoins by amending existing financial services...

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...