On 1 March, a post from Corker Bining said that the UK Government has announced a dramatic change to the legislation that gives HM Treasury the power to impose monetary penalties for a failure to comply with an obligation under financial sanctions legislation (as well as for a breach of a sanctions prohibition). It is said further that, assuming that the Economic Crime (Transparency and Enforcement) Bill 2022 comes into force, this is a remarkably tough new test which ought to make banks and other professionals extremely wary of taking any risk in relation to sanctions targets.
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