Relief from Sanctions: The forewarning of a merits-based escape

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Few words strike fear into the hearts of litigators more than reference to “the Denton principles’. These are the principles which the English court applies when considering an application for relief from sanctions. In other words, the yardstick against which petitions for leniency are measured when there has been a breach of the procedural rules. […]

Michael O'Kane

Peters & Peters acts in first civil monetary penalty case under the UK’s strict liability regime for breaches of financial sanctions

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On 29 August 2024, following an investigation lasting over 15 months, the Office for Financial Sanctions Implementation (OFSI) imposed a monetary penalty of £15,000 against our client, Integral Concierge Services Limited, for contravention of regulations 11(1) and 13(1) of the Russia (Sanctions) (EU Exit) Regulations 2019 (the Russia Regulations). The case involved consideration of the […]

Anna Bradshaw

Lack of clarity remains around UK’s Office of Trade Sanctions Implementation

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Nine months ago, the UK government announced the creation of the Office of Trade Sanctions Implementation (OTSI), a new agency to enforce trade sanctions. Last month, regulations outlining OTSI’s remit and powers were finally introduced. Part of the Department for Business and Trade, OTSI joins the ranks of other agencies already responsible for various aspects […]

Thinking page

NCA recovers £780,000 in the first UK forfeiture of sanctioned funds

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Is this a sign that we are entering a period of stronger and swifter action on sanctions breaches by law enforcement agencies? In this article for LexisNexis Corporate Crime analysis, Liam Lane discusses the key points of this case, the outcome for the National Crime Agency (NCA) and the significance of this case. He also […]

Anna Bradshaw

The Guide to Sanctions – fifth edition

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Anna Bradshaw and Alistair Jones have contributed a chapter to Global Investigations Review‘s Guide to Sanctions, which is in its fifth edition. The guide is written by contributors from the expanding field of sanctions enforcement and dissects the topic in a practical fashion, from every stakeholder’s perspective. The chapter that Anna and Alistair wrote, ‘Representing […]

Liam Lane

NCA ducks litigation risk in first seizure of sanctioned assets

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In the first action of its kind, earlier this week, the National Crime Agency (NCA) secured the forfeiture of sanctioned funds under the Proceeds of Crime Act. The NCA had argued that the money, worth £780,000, was held for the benefit of Russian oligarch Petr Aven despite not being in his name. The money had […]

Michael O'Kane

Sanctions on wealthy figures linked to Russia are Kafkaesque

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Since Russia invaded Ukraine two years ago, the UK, US, EU and other jurisdictions have imposed a plethora of sanctions on Russia, including on business figures who are believed to have links with the Kremlin. In the UK, a designated person can challenge their designation, first to the minister who made the designation and, if […]

Michael O'Kane

Overview of sanction regimes in UK, EU and US

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In this podcast, Michael O’Kane, Maya Lester KC talk to Dr Christian Rosinus, of Rosinus Partner, about sanction law. They begin by outlining the general EU, UK, and US sanctions jurisdictions, highlighting their similarities and differences. Michael then explains the applicability of UK sanctions and Maya addresses the influence of post-Brexit case law by the […]

Michael O'Kane

Eugene Shvidler’s case is going to UK Supreme Court

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The UK Supreme Court has granted permission to Eugene Shvidler to appeal against the Court of Appeal judgment upholding sanctions against him. Michael O’Kane acts for Mr Shvidler. This will be an important case on the UK courts’ approach to targeted sanctions challenges. The UK designated Mr Shvidler in March 2022 for being associated with […]

Michael O'Kane

Watch: sanctions de-listings in the UK, EU and US webinar

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Earlier this week, Michael O’Kane hosted a discussion on the different approaches of the courts and governments in the UK, EU and USA to the issue of removing people and companies from targeted sanctions lists, including analysing recent case law. The recording of the webinar is now available to view. The speakers  – Michael O’Kane, […]