On 15 March, HM Treasury announced that 9 persons had been added to the sanctions lists for conducting or directing cyber activity that undermines, or is intended to undermine, the integrity, prosperity or security of the UK or a country other than the UK; international organisations; and NGO whose purposes relate to the governance of international sport or the Internet.

UK: New measures to tackle corrupt elites and dirty money become law

On 15 March, the Home Office announced that the Economic Crime (Transparency and Enforcement) Bill has received Royal Assent.  A new Register of Overseas Entities, requiring those behind foreign companies which own UK property to reveal their identities, will also be created under the Act.  The new legislation will mean the government can move more quickly to impose sanctions against oligarchs already designated by allies.  Reforms to Unexplained Wealth Orders (UWO) will remove key barriers to their use.

Key supply of diamonds caught up in Russia sanctions

On 14 March, CNN reported that global sanctions against Russia for its invasion of Ukraine are affecting the global supply of a precious commodity – the diamonds used in jewellery.  The ban directly targets Alrosa, which the US government identified as the world’s largest diamond mining company, responsible for 90% of Russia’s diamond mining capacity and accounting for 28%, or nearly a third, of global diamond output.  However, it is said it isn’t clear how US Customs will treat imports of polished diamonds that come from other countries but originated in Russia. A raw diamond can touch many countries as it goes from an uncut gem to a beguiling necklace or ring.

The Key Questions About How Sanctions Affect the Art Market

On 14 March, an article from Artnet set out to answer a sampling of the most common questions received from clients and others in the US and around the world. The bottom line it provides is to think of sanctioned parties as functionally dead to the world, and when in doubt, tell clients not to proceed.

Brookings Sanctions Tracker

On 14 March, the Brookings Institute published this tool, saying that the tracker monitors sanctions in response to the Russian invasion of Ukraine.  The tracker was last updated as of 11 March. The tracker currently includes sanctions announced between 22 February and 10 March.  Given the rapidly evolving situation, this spreadsheet will be periodically updated.


Panama Covid-19 update – numbers still falling,with numbers in ICU nationwide down to only 15. Nevertheless, 146 new cases reported and 3 new fatalities. There are said to be 2,420 active cases,including 108 in other wards.

14 MARCH 2022

Greetings from David (again)!    Still on tour, so still not quite normal service…

Cryptocurrency Industry Breathes a Sigh of Relief Following President Biden’s Executive Order

On 10 March, McDermott Will & Emery published an article saying that the Executive Order on Ensuring Responsible Development of Digital Assets is referred to as the “first-ever, whole-of-government approach” to the cryptocurrency industry. It lays out a national policy across 6 key priorities.  The Order was issued for the stated purpose of “addressing the risks and harnessing the potential benefits of digital assets and their underlying technology”.  The Order primarily calls upon certain regulators to focus on this sector. The industry will determine its true effects when these reports are delivered, and regulations are subsequently enacted.

The Russian Maritime Register of Shipping (RMRS) has been withdrawn from IACS and shipping class societies have started to pull out of Russia

On 13 March, Seatrade Maritime News reported that the International Association of Classification Societies (IACS) Council announced that, after seeking legal advice, RMRS’s membership of IACS was no longer tenable.  Class societies have individually announced their own measures related to Russian operations.

Australia to Sanction Russian Oligarchs

On 14 March, VoA reported that Australia has imposed fresh sanctions on wealthy Russian entrepreneurs because of the Kremlin’s invasion of Ukraine.  Roman Abramovich is among more than 30 individuals sanctioned by Australia. They include the chief executive of Russian energy company Gazprom, Alexey Miller, and the head of Bank Rossiya, Dmitri Lebedev.

Bahamas in talks with CARICOM on decision to impose sanctions on Russia

On 14 March, Eye Witness News reported that the Bahamas is in ongoing conversations with CARICOM members states regarding sanctions.

Bank of Israel issues draft guidelines on cryptocurrency AML/CFT

On 13 March, Street Register reported that the Bank of Israel has published a draft regulation on AML/CFT risk management for the banks facilitating crypto-to-fiat transactions.


EU Regulation 2022/413/EU of 10 March added KHATIBA AL-TAWHID WAL-JIHAD (KTJ) to its sanctions lists.

Record seizures mark Sri Lanka’s rise as a smuggling hub for star tortoises

On 13 March, Mongabay reported that Indian star tortoise is the most smuggled tortoise species in the world, with thousands trafficked annually smuggled out from India, Sri Lanka and Pakistan despite a 2019 total ban on the international trade in the species.

How Russian Oligarchs Are Hiding $100 Million Boats

On 11 March, Vice reported that locating these large luxury boats is the easy part, proving who owns them is another matter.  Mega-yachts, private jets, and penthouses owned by ultra-wealthy individuals are often held through shell companies, which can obscure the identity of the real owner.

Russia Absconds with $10 billion in Aircraft in Response to EU Sanctions

On 10March, OCCRP reported that, after the newest wave of EU sanctions banned not only the sale of aircraft and parts to Russian companies but also access over EU airspace for Russian planes, the country’s airlines responded by absconding with more than 500 planes valued at over $10 billion before they could be repossessed by their lessors

Japan introduces further sanctions on Russia and Belarus

On 14 March, Baker McKenzie reported that the Japanese government recently announced additional sanctions on the Russian Federation and the Republic of Belarus.

Isle of Man – no less than 4 new sanctions notices

On 14 March, the Isle of Man issued a total of 4 news releases –

  • One amended the entry on the terrorism sanctions lists for Mohammed Fawaz KHALED;
  • Another notified 15 other entries on the terrorism sanctions lists also having been amended;
  • In the Iran sanctions lists, the entry for PASSIVE DEFENCE ORGANISATION is amended; and
  • The last concerned the application of the Russia (Sanctions) (EU Exit) (Amendment) (No. 6) Regulations 2022 to the Island, and these amend the trade sanctions against Russia to add to the list of prohibited and restricted goods, aviation and space goods and technology, add a new prohibition on insurance and reinsurance services relating to aviation and space goods and technology, and impose various new aircraft-related sanctions against Russia.

HM Treasury: Webinar on UK sanctions related to Russia

HM Treasury is to host a free webinar on the new Russian sanctions on 17 March on Microsoft Teams.  Speakers will include representatives from the Foreign, Commonwealth and Development Office (FCDO), HM Treasury (HMT), Department for International Trade (DIT), Department for Transport (DfT), Business Enterprise Industry and Skills (BEIS) and other government departments. Register at Eventbrite.

UK export controls webinar on Russian sanctions

Another webinar on Russian sanctions from the UK authorities, in this case a webinar organised by Export Control Joint Unit to hear more about the breadth of UK Sanctions against Russia, will take place on 24 March.  For details see Notice to Exporters 2022/07 –

UK: Economic Crime Act seeks to boost meagre use of Unexplained Wealth Orders

On 11 March, an article from Field Fisher starts by pointing out that a handful of UWO have been obtained over the past 4 years, but success has been limited and their use far more restrained than was initially anticipated.  The new Act will give an attempted boost to UWO by introducing 3 new notable provisions.  It concentrates on the third of these, that costs exposure may be limited in the event that a UWO is successfully overturned by the respondent.

Germany charges former Wirecard chief with fraud and false accounting

On 14 March, the Irish Times and others reported that German prosecutors have charged Markus Braun, the former CEO of the payments company, and 2 other ex-managers with fraud and false accounting in connection with the firm’s collapse last year amid allegations that much of its revenue and assets were faked.

UK Supreme court refuses Julian Assange extradition appeal

On 14 March, Computer Weekly reported that the Supreme Court has refused to hear an application by Wikileaks founder Julian Assange to appeal against extradition to the United States.  The case will now be passed to the Home Secretary, who will make the final decision.


Following the decision of the relevant UN committee on 28 February, EU Regulation 2022/419/EU amends Regulation 1352/2014/EU and adds the Houthis to the list of those subject to sanctions.

UK: Ivory Act 2018 (Commencement No. 2 and Transitional Provision) Regulations 2022

These Regulations bring in many of the enforcement provisions of the Act, with effect from 6 June.  The Act itself prohibits all dealing in ivory, subject to the exemptions set out in sections 2 and 6 to 9.

Canadian Securities Administrators (CSA) alerting all market participants to economic sanctions imposed by the Government of Canada on Russia

On 14 March, a release on Mondo Visione reported that the relevant regulations impose broad categories of sanctions on named Russian nationals and Russian entities. Market participants may be directly affected if they intersect with any of the “designated persons” and their assets or property. While the sanctions apply beyond the scope of Canadian securities law, all market participants are potentially impacted.

ING Luxembourg is facing criminal charges over anti-money laundering shortcomings

On 14 March, Luxembourg Times reported that the Dutch-based bank is facing charges dating from 2018.  In its annual report, ING said it did not expect a material financial effect from the Luxembourg case.

US Treasury Study on Money Laundering and Terrorist Financing in the Art Trade

On 14 March, a post on LexBlog considered a US Treasury report containing the findings and determinations made in carrying out a study into the potential threat.

Estonian Authorities Name Swedbank a Suspect in Laundering Case

On 14 March, BNN Bloomberg reported that Swedbank AB says its Estonian unit has been named a suspect in a money laundering investigation by authorities in Estonia.  Estonia is among Swedbank’s 4 home markets. The others are Sweden, Latvia and Lithuania. It also faces large US fines after failing to prevent criminals from using its operations to launder money. The scandal led to a swath of forced departures from the bank and a $386 million fine imposed by Swedish authorities in 2020.

The Ukraine authorities have claimed that the Ukrainian armed forces seized Russian military vehicles and discovered that the Tigr and Pantsir missile system used Bosch, ZF Group, Danfoss and MANN+HUMMEL parts.


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