Political Restrictions and Trade Limitations | UK Regulatory Forecast for November 2023
In a joint effort to increase awareness and combat gold-related sanctions evasion, the National Economic Crime Centre (NECC) issued a red alert on November 8, 2023. The NECC, a multi-agency unit within the National Crime Agency, OFSI, the FCDO, and the Joint Money Laundering Intelligence Taskforce, aims to provide guidance on making reports of suspected gold-based financial and trade activity.
This alert is part of an enhanced partnership established a year prior, between the UK's Office of Financial Sanctions Implementation (OFSI) and the US's Office of Foreign Assets Control (OFAC). The aim is to align financial sanctions implementation between the two countries.
On the same day, the Financial Action Task Force (FATF), the Egmont Group, and the World Gold Council jointly issued a red alert warning about the misuse of gold as a method to circumvent sanctions.
The Foreign Commonwealth and Development Office (FCDO) and OFSI also issued joint guidance on ownership and control under UK sanctions regimes on November 17, 2023. This guidance can be found on a specified link.
Meanwhile, the UK Export Control Joint Unit has published new guidance for those exporting goods, software, or technology which might be subject to strategic export controls. However, no specific details were provided regarding this guidance.
It's important to note that the guidance issued by OFSI and OFSI provides greater clarity on UK and US Russia-related humanitarian assistance. The clarification states that ordinary private companies in Russia are not deemed to be subject to the control of a designated public official simply because they are based in or incorporated in Russia.
The Court of Appeal judgment in Mints & others v PJSC National Bank Trust & another, handed down in October 2023, discussed the potential argument that President Putin controlled everything in Russia, which might have implications for trade with Russian entities.
The NECC alert and the ongoing commitments between OFAC and OFSI are part of the Regulatory Outlook series. This series allows readers to click expand and read other articles in the series on various topics such as advertising and marketing, bribery, fraud and anti-money laundering, competition, consumer law, cyber security, data protection, employment and immigration, environment, environmental, social and governance, fintech, digital assets, payments, and consumer credit, food law, health and safety, modern slavery, products, regulated procurement, sanctions and export control, telecoms.
Stay informed and vigilant in the fight against economic crime. For more information, visit the NECC's website and the Regulatory Outlook series.
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