Regulatory Blog

On 6 November 2024, the Governor of the Virgin Islands issued a Notice under the Virgin Islands Sanctions Regulations, empowering certain officials and entities to manage and enforce sanctions.

On 7 November 2024, the UK unveiled its largest sanctions package against Russia since mid-2023, aiming to weaken Russia's military and curtail Russian-backed mercenary operations worldwide. With 56 new designations, the sanctions directly impact Russian supply chains essential for military equipment, specifically targeting companies in countries like China, Turkey, and Central Asia that provide critical goods such as microelectronics, machine tools, and drone components.

Following the invasion of Ukraine by Russia, the UK Government, alongside the member states of the European Union, the United States of America and other global stakeholders issued significant new sanctions. View a table of all the sanctions here

In May 2024 the English High Court issued its judgement in Vneshprombank LLC v Bedzhamov which has helpfully clarified a number of matters relevant to interpretation of the UK asset freeze regime on Russia. The learned judge examines what constitutes a “reasonable cause to suspect” under UK sanctions law – providing important guidance on when suspicion of ownership or control by a UK asset-frozen person may arise, particularly after formal ownership transfers.

On 10 October 2024, the UK government launched the Office of Trade Sanctions Implementation under the Department for Business and Trade. This new unit strengthens enforcement of trade sanctions and helps businesses comply with the UK's sanctions regime.

On 15 October 2024, the Governor of the Virgin Islands issued General Licence No. 7 2024 (maintenance of economic resources), replacing the previous General Licence No. 4 2023. This new licence, valid for two years until 14 October 2026, allows Registered Agents and Corporate Services Providers to manage specific payments on behalf of designated individuals or companies, subject to certain limits.

On 13 September 2024, the Council of the European Union (EU) has issued a number of important notices regarding restrictive measures under Council Decision 2014/145/CFSP and Regulation (EU) No 269/2014, as amended and implemented (EU Sanctions), targeting individuals, entities and bodies involved in actions undermining the territorial integrity, sovereignty and independence of Ukraine.

On 30 September 2024, the UK Export Control Joint Unit issued Notice NTE 2024/26, announcing a change in how intra-corporate services between UK parent companies and their Russian subsidiaries will be regulated under the Russia (Sanctions) (EU Exit) Regulations 2019.

On 1 October 2024, the UK in collaboration with the US and Australia, sanctioned 16 key members of the Russian cyber-crime group, Evil Corp. This group has been responsible for destructive cyber-attacks on health, government, and private sectors globally, accumulating hundreds of millions in illicit profits.