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ARTICLE · 04 DECEMBER 2024

Recent Developments In UK Sanctions

WilmerHale
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The UK has updated its sanctions framework, enhancing UK-US collaboration, expanding reporting requirements, introducing civil penalties, and targeting Russian-linked entities and ships. Businesses must refine risk assessments and align controls with evolving regulations...

United StatesInternational Law
Richard Burger
Richard Burger
Zachary Goldman
Zachary Goldman
Lindsey Cullen
Lindsey Cullen
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After a relatively quiet period, UK sanctions updates have picked up pace in recent weeks. We have seen the announcement of an enhanced partnership between US and UK sanctions agencies, updates to reporting requirements, the introduction of new civil penalty powers, and a clarification of asset freeze rules. In addition, new waves of sanctions against Russia's military industrial complex, Russian-backed mercenary groups and Russian oil tankers have been announced.

Enhanced UK/US collaboration

On 19 November 2024, the UK's Office of Financial Sanctions Implementation ("OFSI") announced that its recent meetings with the Office of Foreign Assets Control ("OFAC") in the US had resulted in the signing of a Memorandum of Understanding between the two agencies, which will further support their information sharing and collaboration efforts.1 OFSI also noted that the agencies had conducted joint private sector outreach, and that the OFSI/OFAC reciprocal secondment scheme

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