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Regulatory Blog

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OFSI and FCDO issue joint guidance on ownership and control, following the Boris Mints case
On 17 November 2023, the UK Office of Financial Sanctions Implementation (OFSI) and the Foreign, Commonwealth, and Development Office (FCDO) released joint guidance, addressing the implementation of the UK's ownership and control by public officials, within financial sanctions legislation. The guidance was issued following statements of the English Court of Appeal in the case Mints v PJSC National Bank Trust [2023] EWCA Civ 1132.
Update to UK Sanctions on Russia-Ukraine-Belarus (up to 13 November 2023)
Following the invasion of Ukraine by Russia, the UK Government, alongside the member states of the European Union, the United States of America and other global stakeholders issued significant new sanctions. View a table of all the sanctions here
Landmark ruling by E&W Court of Appeal in the Mints Case on ownership and control and UK Government’s response
On 6 October 2023, the E&W Court of Appeal issued a significant judgment in the case of Mints v PJSC National Bank Trust & Anor [2023] EWCA Civ 1132. As most relevant to sanctions practitioners, the case revolves around the "ownership and control" test under The Russia (Sanctions) (EU Exit) Regulations 2019.
BVI Governor released new legal services General Licence and accompanying reporting requirements
On 13 October 2023, the BVI Governor issued General Licence No. 5 2023 (payment of reasonable professional legal fees and expenses), replacing General Licence No. 3.
BVI Governor's reminder on General Licence for legal service fees under Russia and Belarus regime designations
On 28 September 2023, the Governor of the BVI issued a formal reminder concerning General Licence No. 3 of 2023, which was issued on 13 April 2023. This General Licence authorises the payment of legal service fees to individuals who have been designated under either the Russia or Belarus regime, provided that strict adherence to its specified terms and conditions is observed.
Economic sanctions: 10 practical considerations
When confronted with a sanctions scenario, service providers within the financial services sector must cope with a multitude of significant issues. Below, we provide a brief overview of ten key considerations that service providers should bear in mind in relation to their book of business and their portfolio of clients.
Expert Review – Oil and gas sanctions on Russia
In this episode, Global Head of Regulatory & Tax Aki Corsoni-Husain, and guest expert Ray-Shio Ho from Reed Smith in London explore the oil and gas sanctions currently in place on Russia following the war in the Ukraine in 2022.
Sanctions Circumvention Guidance for European Operators
On 7 September 2023, the European Commission released a guidance note to assist European operators in recognising and avoiding sanctions circumvention risks. This guidance is crucial to ensure compliance with EU law and address the challenges posed by sanctions, especially in response to Russia's aggression against Ukraine.
CySEC's Circular on forced transfers of Russian securities
On 11 September 2023, the Cyprus Securities and Exchange Commission (CySEC) issued Circular 596 regarding Russian Federation Federal Laws No. 319-FZ (Law 319-FZ) and No. 519-FZ (Law 519-FZ), which concern certain transfers of Russian securities, known as forced transfers, further defined below.
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