British Overseas Territories exported $134m worth of goods to Russia in 2024
In 2024, companies registered in British Overseas Territories exported $134m worth of goods to Russia in apparent breaches of UK sanctions. The UK’s Russia sanctions have been extended to overseas territories. The FT’s analysis of Russian filings found several entities based in overseas territories and with unclear ownership records were involved in shipments of controlled exports to Russia.
Cyber sanctions: guidance
As required by the Sanctions Act, the document contains guidance on the prohibitions and requirements imposed by the Regulations. It additionally provides guidance on best practice for complying with the prohibitions and requirements; the enforcement of them; and circumstances where they do not apply. This document is intended to be read alongside more detailed sanctions guidance published by departments including the Home Office and HM Treasury, through the Office of Financial Sanctions Implementation (OFSI). Link
EU widens restrictive measures in view of Iran support of the Russian war of aggression against Ukraine and lists one individual and four entities
The Council decided to widen the scope of the EU framework for restrictive measures in view of Iran’s military support to Russia’s war of aggression against Ukraine and to armed groups and entities in the Middle East and the Red Sea region. This additional measure is targeted to the use of vessels and ports for the transfer of Iranian-made Unmanned Aerial Vehicles (UAVs), missiles and related technologies and components. Council decision introduces a prohibition on the export, transfer, supply, or sale from the EU to Iran of components used in the development and production of missiles and UAVs.
The EU is also introducing a transaction ban prohibiting any transaction with ports and locks that are owned, operated or controlled by listed individuals and entities, or are used for the transfer of Iranian UAVs or missiles or related technology and components to Russia. This measure includes the access to facilities of the ports and locks, such as Amirabad and Anzali, and the provision of any services to vessels. The latter should be understood with the exception of vessels in need of assistance for reasons of maritime safety, for humanitarian purposes, or in relation to events likely to have a serious impact on human health and safety or the environment. Furthermore, the Council adopted restrictive measures against one individual and four entities following Iran’s missile and drone transfers to Russia in support of its war of aggression against Ukraine.
European Banking Association guidelines on sanctions compliance for financial institutions & payment service providers
The European Banking Authority (EBA) published two sets of final Guidelines that, for the first time, set common EU standards on the governance arrangements and the policies, procedures and controls financial institutions should have in place to be able to comply with Union and national restrictive measures. The first set of Guidelines is addressed to all institutions within the EBA’s supervisory remit. They include provisions that are necessary to ensure that financial institutions’ governance and risk management systems are sound and sufficient to address the risk that they might breach or evade restrictive measures.
The second set of Guidelines is specific to payment service providers (PSPs) and crypto-asset service providers (CASPs) and specify what PSPs and CASPs should do to be able to comply with restrictive measures when performing transfers of funds or crypto-assets. The deadline for competent authorities to report whether they comply with the Guidelines will be two months after the publication of the translations into the official EU languages. The amending Guidelines will apply from 30 December 2025.
EU renews human rights sanctions
The EU has renewed its global human rights sanctions regime for 12 months. The sanctions currently apply to 116 people and 33 entities. The regime has been renewed until 8 December 2025. Link
EU maintains several DPRK listings
The EU has published a notice of its intention to maintain sanctions against several individuals and entities listed under its DPRK regime. The 15 individuals and 4 entities affected may request to obtain the information related to maintaining the measures from the Council until 7 November 2024. Link
EU clarifies ‘best efforts’ obligation in Russia Regulation 833
The EU has published FAQs on the obligation under Article 8a of Regulation 833/2014 to undertake best efforts to ensure that entities outside the EU that they own or control do not participate in activities that undermine Regulation 833 sanctions. Link
EU: Targets of EU Tunisia sanctions can request information received from Tunisian authorities
The EU has published a notice stating it will consider information received from the Tunisian authorities in its annual review of sanctions against Tunisia. Those designated on this list have until 11 November 2024 to request information the Council has received from Tunisia which relates to them and submit any observations. Link
Germany arrest for Russia sanctions violations
German police have arrested a man in Nuremberg over suspected sanctions violations. He is said to have violated the Foreign Trade Act through using his Germany-based company to procure maritime goods for final use in Russia. The unnamed suspect allegedly acted as part of an international network. 6 properties have been searched as part of the investigation.
German customs confiscate luxury cars in Russia sanctions investigation
Essen customs and the Würzburg public prosecutor's office are investigating the owner of German car dealership suspected of violating the Foreign Trade Act. The man is said to have exported over €10m-worth of luxury vehicles to Russia. In September 2024, customs searched several properties in Aschaffenburg and confiscated 8 vehicles worth c. €1.5m. Cash and bank balances were also seized.
Guernsey updates handbook on countering financial crime
Guernsey has updated its Handbook on Countering Financial Crime to add, amend and remove various countries under appendices. Gibraltar has been added to Appendix C, which lists ‘equivalent jurisdictions’.
Link
Latvia sanctions enforcement update
Latvia’s State Revenue Service (VID) has initiated 94 criminal proceedings relating to violations of Russia/Belarus sanctions in 2024. These proceedings bring the total number of criminal proceedings initiated in Latvia since sanctions were imposed to over 300. VID has also suspended 2400 customs procedures in 2024. The exports to Russia/Belarus that VID most frequently prevented involved cars, tractors and electrical equipment.
Netherlands proposes major overhaul of EU sanctions enforcement system
The Netherlands has circulated a non-paper – an informal discussion document – proposing to strengthen European cooperation on sanctions implementation and enforcement, calling for new EU-wide risk assessments, minimum enforcement standards and enhanced compliance rules for high-risk businesses.
Link
Poland charges German national for exporting dual-use goods to Russia
Polish authorities have arrested and charged a German national for brokering and exporting dual-use goods to Russia, in breach of EU sanctions. According to the prosecution, the suspect "allegedly acted as an intermediary in the sale and export outside the territory of the European Union of dual-use machines, which can be utilized for both civilian and military purposes, in order to gain financial profit." A German foreign office source said the embassy in Warsaw was in touch with Polish authorities and working urgently to get details.
SECO: Ordinance in relation to the situation in Moldova
The Federal Department of Economic Affairs EAER has amended the annex of the Ordinance instituting measures in relation to the situation in Moldova. Five individuals and one entity have been added to the annex. The measures come into force at 6 pm on 8 November 2024. Link
SECO - Sanctions: Ordinance on Measures against Individuals and Entities Associated with Usama bin Laden, the Group «Al-Qaïda» or the Taliban
04.12.2024 - The UN sanctions committee has amended the list of sanctioned individuals, companies and organizations. The SESAM database has been updated accordingly Link
SECO - Sanctions: Ordinance imposing Measures connected with the Situation in Ukraine
The State Secretariat for Economic Affairs (SECO) published an application form to be completed for requests for a derogation based on art. 15 para. 5 of the Ordinance imposing measures connected with the situation in Ukraine (RS 946.231.176.72). The application form as well as all the details and requirements can be found on the page dedicated to requests for derogation on the SECO website. Link
Switzerland adopts EU sanctions against Belarus
Switzerland has adopted further EU sanctions against Belarus. In June 2024, the EU imposed additional sanctions measures against Belarus, which included:
- Expanding the list of goods subject to an export/import ban;
- Prohibiting certain services related to (inter alia) accounting and auditing;
- Introducing new transport prohibitions; and
- Requiring EU operators to contractually prohibit the re-exportation to Belarus of sensitive goods and technology. Link
UK regulator reports on sanctions compliance among law firms
The UK’s Solicitors Regulation Authority (SRA) has published its annual report on anti-money laundering (AML). The report includes a review of law firm compliance with financial sanctions in 2023-4. Sanctions Inspections: The SRA conducted 55 sanctions inspections. They found: 40 firms were compliant; 6 were partially compliant; and 9 were referred for investigation over non-compliance. Link
UK: New UK application system for SIELs extended to other exports
Applications for SIELs relating to control entries 1C353a1, 1C353a2, 1C353a3 (category 'Genetic elements’ and ‘genetically-modified organisms) were removed from the table in the 'when not to use this service' section. Link
UK: HMRC compound settlement for breaches of Russian sanctions
HM Revenue and Customs (HMRC) has issued a compound settlement offer to a UK exporter of just over £58,000.00.
- August 2024 - £58,426.45 was paid relating to the export of goods in breach of The Russia (Sanctions) (EU Exit) Regulations 2019
Following Russia’s illegal invasion of Ukraine, the UK and our international partners have implemented the most severe package of sanctions ever imposed on a major economy, which has deprived the Russian state of over $400 billion in funding for its war machine.
Failure to comply with these sanctions is a serious offence and those who breach them may be subject to a range of enforcement actions, including large financial penalties or referral for criminal prosecution.
UK removes a licensing ground for sanctioned trade services under Russia regime
The UK has updated its licensing grounds for applying for a licence to provide sanctioned trade services under its Russia regime. The following licensing ground has been removed: services to a person connected with Russia by a UK parent company or UK subsidiary of that parent company.
UK updates import licensing system for sanctioned countries
OFSI has updated its import licensing process, amending guidance for sanctions programmes targeting Iran, Belarus, North Korea and the Central African Republic, the office announced 19 November.
The changes affect guidance documents for the Iran (Sanctions) (Nuclear) (EU Exit) Regulations 2019, Democratic People’s Republic of Korea (Sanctions) Regulations 2019, Republic of Belarus (Sanctions) Regulations 2019, and Central African Republic (Sanctions) Regulations 2020.