OFSI’s New Monetary Penalties Signal a Broader and Extraterritorial Approach to U.K. Sanctions Enforcement

April 10, 2017
By: Anna Sayre, Legal Content Writer, SanctionsAlert.com

As of April 1, 2017, the U.K.’s new sanctions watchdog, Office of Financial Sanctions Implementation (OFSI) is now able to impose monetary penalties for breaches of financial sanctions. These fines can be imposed for up to £1 million or 50% of the breach, whichever is greater. (more…)

Russian ‘Mirror Trading’ Case Reveals Five Long-Running Compliance Failures at Deutsche Bank

March 9, 2017
By: Anna Sayre, Legal Content Writer, SanctionsAlert.com

On January 30, 2017, the New York State Department of Financial Services (DFS), NY’s financial watchdog, as well as the Financial Conduct Authority (FCA), financial services regulator in the UK,ordered Deutsche Bank to pay $425 million and £163 million, respectively, for violations of anti-money laundering regulations and continual, wide spread compliance failures. The so-called ‘mirror trading” scheme, involving the German lender’s Moscow, London and New York offices,resulted in $10 billion being transferred out of Russia. (more…)

Monetary Sanctions Consultation Released by UK’s OFSI Points to Stricter Sanctions Enforcement

December 19, 2016
By: Anna Sayre, Legal Content Writer, SanctionsAlert.com

Companies, individuals, and financial institutions may receive monetary penalties under civil law when breaching financial sanctions under a new proposal by the UK government that could shape the future of financial sanctions enforcement.

Calling for responses to a consultation document by January 26, 2017, the UK Office of Financial Sanctions Implementation (OFSI) has said the planned changes will allow “more flexible, effective and proportionate set of enforcement measures”. (more…)

New UK study aims to track trends in money flowing into WMD programs

October 4, 2016
By: Jonathan Brewer

Seventy five years after the first use of an atomic bomb, the proliferation of weapons of mass destruction (WMD) continues to be a threat to international peace and security. Each year, governments invest major resources in combating the quickening spread of WMD, which include nuclear weapons. Examples are the disrupting of the procurement networks, prosecuting the individuals and companies involved, and disrupting the money flow. (more…)

Sanctions: Brainteasers With Serious Consequences

By: Davina Given*

Failure to comply with financial sanctions carries serious penalties, most notably in the US, where banks have collectively paid billions of dollars in fines.  Even in the UK, a failure to comply with sanctions carries the potential for unlimited criminal and regulatory fines and/or imprisonment.  Yet financial sanctions are often difficult for most businesses to grapple with, particularly if they do not have the resources of the very largest businesses.  Political imperatives may lead to the imposition of financial sanctions in respect of existing, longstanding business.  Individual targets may change quickly and abruptly, with little fanfare.  Different countries involved in a transaction may apply slightly different financial sanctions, so that the transaction may be legal in one country but illegal in another.  Yet on top of those issues, there is a further legal difficulty: what does any particular financial sanction actually prevent? (more…)