The lack of enforcement decisions at this stage provides limited guidance about interpretation of the rules. In light of the potential severity of penalties for breaches of sanctions, the very real reputational risks and particularly given the strict liability test introduced, we recommend that a cautious approach is adopted by businesses in transactions with other businesses, regimes and individuals which are sanctioned.
The Russia (Sanctions) (EU Exit) Regulations 2019 ("the Regulations") impose financial, trade, transport and immigration sanctions to encourage Russia to cease actions which destabilise Ukraine, including actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine. In the UK, the Office of Financial Sanctions Implementation ("OFSI") expects all businesses who engage in activities where financial sanctions apply to stay up to date with the sanctions regimes in force. Alongside considering likely sanctions exposure, businesses must also take appropriate steps to mitigate those risks.
Companies may prefer to comply with standards higher than their strict legal requirements to protect themselves against indirect and/or reputational risks. In this webinar DWF experts will start with providing an overview of the aims of international sanctions and then discuss the evolution and development of sanctions following Russia's invasion of Ukraine in February 2022. We will look at:
- the impact of sanctions on particular sectors including shipping and banks, identifying how certain companies continue to evade sanctions;
- what compliance checks should be undertaken to ensure that contracting parties are not breaching sanctions rules, focusing on how to avoid common pitfalls;
- what might be the future effects of sanctions.
