Day: June 23, 2022

On 23 June, FATF released this White Paper, saying that it is conducting a review of Recommendation 25 on the transparency and beneficial ownership of legal arrangements.  The objective is to improve R.25 and its Interpretive Note to better meet its stated objective to prevent the misuse of legal arrangements for money laundering or terrorist financing.  FATF’s work in this area is ongoing, and will benefit from hearing views from stakeholders, including trustees, financial institutions, designated non-financial businesses and professions (DNFBP), and non-profit organisations (NPO).  Responses are due by 1 August.

https://www.fatf-gafi.org/publications/fatfrecommendations/documents/r25-public-consultation.html

Any modest contributions for my time and ongoing expenses are welcomed!  I have a page where you can do so, and where one-off contributions start as low as $3, at

https://www.buymeacoffee.com/KoIvM842y

NOTE THAT THE ABOVE LINK IS NOW CORRECTED AND WORKS!

On 22 June, CSIS published a review, in the form of a Q&A, of their impact and effect.  It assesses the effect Western sanctions are having on the Russian economy and war effort, evaluates additional potential sanctions, and discusses lessons learned for economic statecraft.

https://www.csis.org/analysis/strangling-bear-sanctions-russia-after-four-months

Any modest contributions for my time and ongoing expenses are welcomed!  I have a page where you can do so, and where one-off contributions start as low as $3, at

https://www.buymeacoffee.com/KoIvM842y

NOTE THAT THE ABOVE LINK IS NOW CORRECTED AND WORKS!

On 23 June, the Department for International Trade published this amended Notice to Importers on 21 June to reflect the implementation of new import sanctions measures that relate to certain ‘revenue generating goods’. The new measures also extend to the provision of ancillary services related to certain iron and steel products.

https://www.gov.uk/government/publications/notice-to-importers-2953-russia-import-sanctions/nti-2953-russia-import-sanctions

NOTICE TO EXPORTERS 2022/18: INTRODUCTION OF ADDITIONAL SANCTIONS AGAINST RUSSIA

https://www.gov.uk/government/publications/notice-to-exporters-202218-introduction-of-additional-sanctions-against-russia

UK: RUSSIA (SANCTIONS) (EU EXIT) (AMENDMENT) (No 10) REGULATIONS 2022

These Regulations, which come into operation on 23 June, impose new restrictions. 

https://www.legislation.gov.uk/uksi/2022/689/pdfs/uksiem_20220689_en.pdf

https://www.europeansanctions.com/2022/06/uk-adopts-further-russia-trade-sanctions/

Any modest contributions for my time and ongoing expenses are welcomed!  I have a page where you can do so, and where one-off contributions start as low as $3, at

https://www.buymeacoffee.com/KoIvM842y

NOTE THAT THE ABOVE LINK IS NOW CORRECTED AND WORKS!

An article from Oppenhof & Partner in Germany on 22 June considers new FAQ from the EU on interpretation of the sanctions on Russia.  It starts by saying that, generally, a listed person holds an ownership position in a third party in case of a majority shareholding, i.e. if the listed person holds more than 50% of the shares in the company (so-called “50% rule”).  However, the updated FAQ says that “One should take into account the aggregated ownership of the entity.  For example, if one listed person owns 30% of the entity and another listed person owns 25% of the entity, the entity should be considered as owned by listed persons“. 

https://www.mondaq.com/germany/export-controls-trade-investment-sanctions/1204416/russia-sanctions-minority-shares-of-sanctioned-persons-in-non-listed-companies-to-be-aggregated-in-future-further-non-sanctioned-companies-possibly-also-affected

Any modest contributions for my time and ongoing expenses are welcomed!  I have a page where you can do so, and where one-off contributions start as low as $3, at

https://www.buymeacoffee.com/KoIvM842y

NOTE THAT THE ABOVE LINK IS NOW CORRECTED AND WORKS!

A blog post from Mark Elliott, Professor of Public Law and Chair of the Faculty of Law at the University of Cambridge, considers the new UK Bill of Rights Bill, which would replace the European Convention on Human Rights in UK law.  He looks at what will not change; what would change; and the broader implications of the Bill in terms of human rights protection in the UK.  He claims the effect of the Bill would be to reduce available rights and (as with the Northern Ireland Bill post-Brexit) is based on a false idea – that it is possible to legislate domestically in order somehow to manipulate or magic away treaty obligations that are binding upon the UK as a matter of international law; and that so long as it remains party to the ECHR it is bound by it, regardless of what the Bill might say.

https://publiclawforeveryone.com/2022/06/22/the-uks-new-bill-of-rights/

Any modest contributions for my time and ongoing expenses are welcomed!  I have a page where you can do so, and where one-off contributions start as low as $3, at

https://www.buymeacoffee.com/KoIvM842y

NOTE THAT THE ABOVE LINK IS NOW CORRECTED AND WORKS!

On 20 June, Osborne Clarke reported that, on 17 June, the UKFIU had released an update on suspicious activity reports (SAR) glossary codes and reporting routes, which replaces the previous guidance on this topic.  SAR glossary codes allow the UKFIU to conduct further analysis to identify money laundering trends, high-risk cases for development and to take immediate action where necessary. It is possible to have a SAR with several codes (or no code may apply at all).  There are new codes for SAR where the value is less than £3,000 and where one is unaware of any existing law enforcement interest at the time of reporting.

https://www.osborneclarke.com/insights/suspicious-activity-reports-uk-financial-intelligence-unit-issues-new-guidance

Any modest contributions for my time and ongoing expenses are welcomed!  I have a page where you can do so, and where one-off contributions start as low as $3, at

https://www.buymeacoffee.com/KoIvM842y

NOTE THAT THE ABOVE LINK IS NOW CORRECTED AND WORKS!