In its 2019-2020 Annual Report (the Report), the UK’s sanctions office (the UK Office of Financial Sanctions Implementation (OFSI)) revealed that, between April 2019 and March 2020, it had received 140 voluntary disclosures of potential sanctions violations related to transactions worth a total of £982 million.  This represents a record number of reports, and an

In light of the recent protests in Iran, a UK press report has recently drawn attention to a motion – known as Early Day Motion 483 – filed in October by a Conservative Party MP to designate Iran’s Islamic Revolutionary Guard Corps (“IRGC”) as a terrorist organisation.

The motion calls upon the UK Government to include the IRGC on the list of “proscribed organisations” and to impose “punitive measures” against its individuals.  Since its filing, the motion has collected 70 signatures from MPs from various parties, including the Conservative Party, the Labour Party, the Scottish National Party, Plaid Cymru, the Liberal Democrat Party and the Democratic Unionist Party.

While Early Day Motions can be debated, most are not.  Instead they are typically used to draw attention to a particular topic or to record the views of those MPs that lend their signatures.  For example, the official UK Parliament website notes that during the 2015-2016 parliamentary session a total of 1,457 Early Day Motions were filed.  With the House of Commons back in session after the Christmas break, it remains to be seen whether Early Day Motion 483 gets debated. 
Continue Reading UK MPs Seek to Designate Iran’s Islamic Revolutionary Guard Corps a Terrorist Organisation

A couple of recent news items throw into sharp relief what we long have noted here at the International Compliance Blog—that economic sanctions are a key tool of a country’s national security and foreign policy, and can serve as an instrument by which to influence a broad array of events.

First, take a look at this photo:

President Donald Trump receives a briefing on a military strike on Syria from his National Security team

This is an official White House photo of President Trump and members of his administration receiving a top secret briefing, in the Secure Compartmentalized Information Facility (SCIF) at the President’s Mar-a-Lago estate, regarding the recent cruise missile strikes against Syria.  The New York Times, BBC, and CNN have scrutinized the photo to decipher its implications for various palace intrigues, noting which administration officials were in the room, who was not in the room, and who was seated where.

Palace intrigues aside, the photo raises an interesting question for our purposes—why were Treasury Secretary Steven Mnuchin and Commerce Secretary Wilbur Ross in the room?

Both the Times and BBC have speculated that they were included in the briefing because they were at Mar-a-Lago to meet with Xi Jinping, the President of China, and were invited simply because they were already onsite.

But let’s consider a different view—that the Treasury and Commerce Secretaries attended because the Treasury and Commerce Departments are part of the national security apparatus of the United States. 
Continue Reading What’s in a Photo? And Thoughts on the UK Sanctions Scene

Following up on our previous post, yesterday the UK Office of Financial Sanctions Implementation (OFSI) issued regulations formally implementing the civil penalties framework set out in the Policing and Crime Act 2017.  OFSI has issued a press release, regulations regarding civil penalties, responses received to OFSI’s request for consultation regarding draft guidance

The UK’s Office of Financial Sanctions Implementation will soon issue regulations that could significantly alter the British sanctions enforcement environment, and bring it closer in line with the US’s approach to such violations.  On the heels of the newly-enacted Policing and Crime Act 2017, the regulations will introduce civil penalties for the violation of financial