On 12 September 2024, His Majesty’s Government (HMG) published the Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 (Regulations), introducing new civil enforcement powers
Continue Reading UK Announces New OTSI Civil Enforcement Powers on Trade SanctionsGavin Costelloe
Gavin Costelloe is a member of Greenberg Traurig’s White Collar Defense & Special Investigations Practice in London. Gavin is a former lawyer and prosecutor for the UK’s Serious Fraud Office (SFO). Gavin advises companies and individuals on internal, government and regulatory investigations and compliance issues related to the UK Bribery Act, fraud, market manipulation, anti-money laundering, economic sanctions, and other serious and complex cross-jurisdictional matters. Gavin has considerable experience assisting with diligence for mergers, acquisitions, and other investments including in jurisdictions with high corruption risk.
Gavin’s practice is focused on business crime investigation, defence, compliance, and risk mitigation. This includes assisting companies with internal, government, and regulatory investigations (including those conducted by the SFO, Her Majesty’s Revenue & Customs (HMRC), the Crown Prosecution Service (CPS) and the Competition and Markets Authority (CMA)), individual defence for senior executives and compliance professionals, and devising and implementing internal training and compliance progammes.
OFSI Issues Licensing Guidance for Payments to Personal Staff of Designated Persons
The UK’s Office of Financial Sanctions Implementation (OFSI) has issued guidance on when payments can be made to personal staff of designated persons (DPs).[1]…
Continue Reading OFSI Issues Licensing Guidance for Payments to Personal Staff of Designated PersonsUK Announces New Office of Trade Sanctions Implementation
On 11 December 2023, His Majesty’s Government (HMG) announced that it will create a new unit – the Office of Trade Sanctions Implementation (OTSI) within…
Continue Reading UK Announces New Office of Trade Sanctions ImplementationUK Court of Appeal Expands Scope of ‘Control’ Under Russia Sanctions Regulations: ‘Mr Putin could be deemed to control everything in Russia’
In a judgment handed down on 6 October, a UK Court of Appeal (the Court) provided an obiter, or non-binding, ruling expanding the scope…
Continue Reading UK Court of Appeal Expands Scope of ‘Control’ Under Russia Sanctions Regulations: ‘Mr Putin could be deemed to control everything in Russia’No Breach Too Small: OFSI Reports First Breach of UK’s Russian Sanctions Regulations
On 31 August 2023 the UK’s Office of Financial Sanctions Implementation (OFSI) issued a “Disclosure” against Wise Payments Limited, a UK-registered company, regulated by the…
Continue Reading No Breach Too Small: OFSI Reports First Breach of UK’s Russian Sanctions RegulationsUK Government General Licence Reduces Breadth of Recent Sanctions-Related Legal Advisory Services Ban
On 11 August 2023, the UK Department for Business and Trade issued a General Licence authorising the provision of legal advice in relation to sanctions…
Continue Reading UK Government General Licence Reduces Breadth of Recent Sanctions-Related Legal Advisory Services BanOFSI Updates Guidance on Refusing Licences
HM Treasury announced 26 July that the UK’s Office of Financial Sanctions Implementation (OFSI) has amended Section 6.12, Refusal of a licence, of its UK…
Continue Reading OFSI Updates Guidance on Refusing LicencesUK Imposes New Russia Sanctions on 86 People and Companies, Including Metal and Diamond Industries
These sanctions have been revealed following an announcement by the leaders of the G7 at this week’s G7 summit where they pledged to take action against Russia and as far as possible restrict its revenue and ability to continue the war against Ukraine. …
Continue Reading UK Imposes New Russia Sanctions on 86 People and Companies, Including Metal and Diamond Industries
New UK Sanctions Package Would Target Russia’s Arms Exports, Front-Line Resources
The UK announced a further round of sanctions and trade measures on 24 February 2023 to coincide with the first anniversary of Russia’s invasion of…
Continue Reading New UK Sanctions Package Would Target Russia’s Arms Exports, Front-Line ResourcesOFSI’s Annual Review Highlights Effect of Sanctions on Russia
On 10 November, the UK’s Office of Financial Sanctions Implementation (OFSI) published its annual review for the period April 2021 to August 2022, with a…
Continue Reading OFSI’s Annual Review Highlights Effect of Sanctions on Russia