Jurisdiction(s):
United Kingdom

UK Sanctions 2023–24 for Lawyers: OFSI and HMRC Enforcement, New Restrictions and Reporting Duties, Russia Focus, Oil Price Cap Compliance, and OTSI’s Launch

Published on: 12 March 2024

Published by a LexisNexis Corporate Crime expert

Legal News

Article summary

Throughout 2023 and into early 2024, attention was firmly fixed on the implementation and enforcement of sanctions under the UK’s autonomous post‑Brexit regime, with Russia the prime focus. Per the most recent officially reported data, as at 31 March 2023 the UK’s consolidated list of financial sanctions targets, maintained by the Office of Financial Sanctions Implementation (OFSI), named 3,883 designated persons. Those individuals and entities were subject to an asset freeze (or other restrictions) across 35 sanctions regimes. These totals are likely to have increased substantially over the past 12 months, and we expect them to rise further between now and the end of the year. Alongside the expansion of the roster of sanctioned persons, 2023 also brought a suite of new financial and trade prohibitions. Measures introduced under the Russia regime have included limits on providing trust services and legal advisory services. Over 90% of the Russian banking sector is now within scope of sanctions, and curbs apply to dealings in money market instruments and securities, as well as granting new loans, entering into new credit arrangements, or other forms of investments that involve persons connected with Russia...

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