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UK Sanctions Update: OFSI Releases Financial Services Threat Assessment – Part 1

By Richard Gibbon, Hannah Laming, Katy Fisher and Grace King on Posted in Anti-corruption, Anti-money laundering, Anti-terrorism financing laws, Communist Party, Compliance Program, Cyberattack, Cybersecurity, Data Protection & Privacy, Economic sanctions, Fraud, Industry Investigations, Money Service Business, Multilateral Development Bank, Office of Financial Sanctions Implementation, Russia, Sanctions, Sanctions, Ukraine, United Kingdom
In February 2025, the UK’s Office of Financial Sanctions Implementation (“OFSI”) issued a report outlining its assessment of the sanctions-related threats posed to the UK by firms operating in the UK’s financial services sector.  As to be expected, the report focuses on the risks associated with transactions since February 24, 2022, when Russia invaded Ukraine … Continue Reading

The Chevron Reversal and Sanctions Litigation

By Tom Firestone on Posted in Anti-corruption, Commercial Bribery, Compliance Program, Corporate compliance, Corruption, Courts, Economic sanctions, OFAC, Office of Financial Sanctions Implementation, Sanctions, Sanctions, United States, US Department of Justice, US Treasury
With the recent SCOTUS decision overturning Chevron, lawyers involved in administrative litigation are considering how the decision will affect their matters.  Sanctions litigation is one area which will be impacted.  Now, when sanctions designations are challenged in court, the government will no longer be able to simply invoke Chevron deference and Specially Designated Nationals (“SDNs”) … Continue Reading

United States Departments of Treasury, Commerce, and Justice Issue “Tri-Seal” Compliance Note on Voluntary Self-Disclosures of Potential Violations

By Kevin McCart, Richard Gibbon, Sassi Riar and Malak Abbas on Posted in Compliance Program, Corporate compliance, Courts, Department of Justice, Economic sanctions, OFAC, Office of Financial Sanctions Implementation, Sanctions, Sanctions, US Department of Justice, US Treasury
Earlier this year, we published a post on the first Tri-Seal Compliance Note (“First Note”) issued by the United States Department of Justice’s (“DOJ”) National Security Division (“NSD”), the Department of Commerce’s Bureau of Industry and Security (“BIS”), and the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”).[1]  When issuing the First Note, … Continue Reading

Increasing US Enforcement Action for Sanctions Violations by Crypto Exchanges Likely to Have Ripple Effect in UK and Europe

By Hannah Laming, Matthew Kirk and José María Viñals on Posted in Cryptocurrency, Economic sanctions, Middle East, OFAC, Office of Financial Sanctions Implementation, Sanctions, Sanctions, United Kingdom, United States, US Treasury
The investigation and enforcement of potential sanctions violations by crypto exchanges is an area of focus in the US at present.  The US Department of the Treasury’s Office of Foreign Assets Control’s (OFAC) recent settlement with Kraken, a global virtual currency exchange, is the most recent OFAC case demonstrating the risks for virtual currency platforms … Continue Reading

The UK’s OFSI Provides Guidance on Strict Liability Sanctions Breach Penalties

By Squire Patton Boggs on Posted in Corporate compliance, Economic sanctions, Office of Financial Sanctions Implementation, Sanctions, Sanctions, United Kingdom
The Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, which is the authority for implementing financial sanctions in the UK, have published guidance to clarify how they will use their new powers to impose civil monetary penalties for sanctions breaches on a strict liability basis from Monday 15 June 2022.  The full message … Continue Reading

OFSI Russian Sanctions Penalty; Foreshadows Increasing UK Enforcement?

By Kevin McCart and Richard Gibbon on Posted in Economic sanctions, Office of Financial Sanctions Implementation
On March 31, 2020, the United Kingdom’s Office of Financial Sanctions Implementation (OFSI) levied its largest monetary penalty to date of GBP 20.47 million. OFSI penalized Standard Chartered for loans to Denizbank, a Turkish bank that was majority owned by Sberbank, a state-owned Russian bank.  Accordingly, those loans violated European Union restrictions on making certain … Continue Reading
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