This edition highlights the latest sanctions round-up, providing an overview of recent developments in UK and global sanctions enforcement and implementation.
Key developments include:
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Sanctions Enforcement: HMRC has charged Hauser & Wirth’s London gallery with breaching Russia sanctions by making a high-value artwork available to a person “connected with Russia”, believed to be the first prosecution of its kind under the UK’s luxury goods ban.
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Compliance Guidance: HMRC has published a case study on its largest ever Russia-related compound settlement (£1.16m), outlining lessons around third-country risk, keeping abreast of sanctions changes, and understanding the scope of “connected with Russia”.
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Sanctions Evasion: The NCA has issued a new Amber Alert examining “shadow fleet” activity used to circumvent restrictions, building on earlier alerts targeting similar networks.
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UK Sanctions Implementation: The Government has imposed asset freezes on the New IRA (and a suspected member) under the domestic counter-terrorism sanctions framework, it's second use of measures imposed under the counter-terrorism regime in relation to Northern Ireland.
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Parliamentary Insight: A new House of Commons Library report assesses how third countries such as Belarus, Iran, North Korea, and China, facilitate Russian sanctions evasion, and examines the implications of divergences between US, EU, and G7 approaches.
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Global Developments: Gazprom has agreed to divest its majority stake in Serbia’s NIS following OFAC pressure; the US has granted Hungary a one-year exemption from Russian energy sanctions; and research indicates that Australia continues to receive large volumes of Russian-origin fuel via third countries, prompting calls for tighter measures.
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