Category: Sanctions

Sanctions Against Ireland’s Top Drug Trafficker May end “Super Cartel’ Allegations

Sanctions
Recent sanctions imposed by the United States on the Kinahan Clan, arguably Ireland’s most powerful organized crime group, have brought to the fore this group’s role in cocaine trafficking between South America, the United States, Europe and beyond. On April 11, the US Treasury Department designated Irish national Daniel Kinahan and six of his associates for smuggling cocaine from South America to Europe as part of the powerful drug trafficking syndicate known as the “Kinahan Clan,” among other things. “Daniel Kinahan, who sources large quantities of cocaine from South America, plays an integral part in organizing the supply of drugs…

U.S. Citizen Who Conspired in Evading Sanctions Sentenced to Over Five Years and Fined $100,000

Prosecutions, Sanctions
A U.S. citizen who conspired to provide services to the Democratic People’s Republic of Korea (DPRK or North Korea), including technical advice on using cryptocurrency and blockchain technology to evade sanctions, was sentenced to 63 months in prison after pleading guilty to conspiracy to violate the International Emergency Economic Powers Act (IEEPA). According to court documents, Virgil Griffith, 39, began formulating plans as early as 2018 to provide services to individuals in the DPRK by developing and funding cryptocurrency infrastructure there, including to mine cryptocurrency. Griffith knew that the DPRK could use these services to evade and avoid U.S. sanctions,…

Brazil Charges President with Illicit Enrichment Ahead of Elections

Prosecutions, Sanctions
Prosecutors charged Brazilian President Jair Bolsonaro with illicit enrichment, in a case related to his former maid in Rio de Janeiro who allegedly received a salary as a government employee while he served as a lawmaker in Brasilia. At the same time, the Brazilian Superior Court ordered a former prosecutor to pay the equivalent of some US$15,000 to Bolsonaro’s political rival, former President Luiz Inacio Lula da Silva, for alleged “moral damages” he caused when he portrayed during a press conference Lula as the leader of a criminal network. The moves come at a sensitive time when Lula is expected…

Economic Crime Act Has Loopholes

Sanctions
A new UK government act designed to target the assets of Russian oligarchs and other money launderers comes with loopholes, according to an economic crime expert from the University of Portsmouth. Paul Gilmour, from the University’s School of Criminology and Criminal Justice is a leading expert on financial transparency, and publishes a new paper today in the Journal of Financial Crime. In it, he says that authorities need to fundamentally adapt their approach to combating money laundering, and strengthen measures to further enhance beneficial ownership transparency. Gilmour is concerned that new measures within the Economic Crime Act, which was recently…

Foreign Secretary Announces Historic Round of Sanctions on Russia

Sanctions
Liz Truss announces historic round of sanctions, taking the overall number of UK sanctions on Russia to more than 1,000 since the invasion of Ukraine. Foreign Secretary announces more than 370 new sanctions now possible thanks to new urgent Economic Crime Act powers after today the UK will have designated over 1,000 individuals and entities under the Russia sanctions regime since the invasion today’s designations also include Putin’s key political allies, regime spokespeople and Kremlin-backed disinformation agencies Foreign Secretary Liz Truss announces over 370 more Russian and Belarussian sanctions today (Tuesday 15 March), which means by the end of today…

Russia Considers New Anti-Transparency Measure to Shield Civil Servants From Sanctions

Regulation, Sanctions
On Mar. 5, 2022, a veteran Russian parliamentarian introduced an amendment to shield Russian civil servants from sanctions “by unfriendly states,” the latest in a series of moves by the Russian government to limit transparency. Sanctioned Parliamentarian Introduces Anti-Transparency Amendment Vladislav Reznik, a deputy since 1999 in the Russian Federation’s State Duma, introduced the proposed amendment to Russia’s Federal Law No. 273-FZ of December 25, 2008, according to Russian news agency Interfax and state media outlet TASS. The proposed amendment would prohibit Russian government entities at all levels (federal, federal subjects, and local) as well as state companies and public…

U.S. Departments of Treasury and Justice Launch Oligarch Whistleblower Programme

Regulation, Sanctions
The US Department of Treasury’s Financial Crimes Enforcement Network has created a new whistleblower programme that will pay more than $5 million to any whistleblower with original information that helps them seize assets of Russian elites seeking to evade US sanctions. Titled the Kleptocracy Asset Recovery Rewards Program, the scheme is aimed at seizing stolen assets by elites and their associates and the proceeds of their corruption. The Treasury Secretary can authorise greater amounts than $5 million should a case merit it. Jeffrey Newman, a partner in the firm of Newman & Shapiro which represents whistleblowers worldwide, said:“This programme can…

You Cannot Just Take an Oligarch’s London home

Sanctions
It has taken Russia’s invasion of Ukraine for the UK to pursue more concerted action against the flow of dirty money through the City of London and the capital’s property market. Government reforms announced on Monday focused on lifting the veil of secrecy around corrupt real-estate ownership. These are just the first steps toward potentially seizing assets — but the steps are significant. Multimillion-pound properties in London have proved a convenient and safe place to stash Russian fortunes. Hereon, anonymous foreign beneficiaries of British real estate are to face restrictions on selling if they hide behind shell companies. Whether these…

Super Yacht Detained in Canary Wharf

Sanctions
Officers from the National Crime Agency’s Combating Kleptocracy Cell have this morning served a detention notice on a superyacht owned by a Russian national. Following some fast-paced work by intelligence officers in the Cell – supported by colleagues from Border Force Maritime Intelligence Bureau – the ultimate owner of the vessel Phi was identified. This information was passed to Transport Secretary Grant Shapps MP, who today ordered the first ever detention of a superyacht in UK waters. As a result NCA officers issued the notice of detention. Owned by a Russian businessman, Phi is the third biggest yacht built by…

Six Steps Exchanges Can Take to Comply With Cryptocurrency Sanctions

Digital Currencies, Sanctions
With the Russian invasion of Ukraine ongoing and extensive sanctions being levied accordingly, cryptocurrency-specific designations may be close behind. Below, we outline six steps exchanges can take to strengthen compliance. 1) Collect Know Your Customer (KYC) information and screen it against sanctions listsAny cryptocurrency business should explore collecting KYC information from new users upon sign-up, recording information such as customer names, addresses, phone numbers, emails, and related documentation. As part of the KYC process, cryptocurrency businesses should screen this information against sanctions lists to refrain from doing business with any designated individuals, entities, or with sanctioned countries. Because each country…

Jewellery Industry Accused of Silence over Russian Diamonds

Sanctions
Insiders say current sanctions do nothing to halt flow of Russian gems to the west because majority are exported rough and get reclassified in India In the photographs, Vladimir Putin stands with a faint smile on hisface. Behind him, the enormous cavern of a mine stretches out, the earth ringed red and ochre. In other photographs from his visit to the Siberian mining city of Mirny, the Russian president is pictured meeting local miners and inspecting one of the dark stones they cut from the earth. Soon, the rock in his hand will be swept into a vast and complex…

German Resort’s Rift Over Russian Oligarch Resonates Across Country

Sanctions
FRANKFURT — A German politician who mobilized a protest against a now-sanctioned Russian resident of his resort town has attracted a following, but also angry emails and a threatening phone call. This mirrors Germany’s ambivalence to becoming a sanctuary for wealth in a culture that cherishes privacy but that critics say has allowed the mega-rich to squirrel away assets in secrecy. And while Britain, France, Italy and Spain have seized yachts and other property since Russia’s invasion of Ukraine and the subsequent imposition of sanctions on influential Russians, Germany appears to have sat on its hands. “For years, Germany has…

Swiss Banks Hold More Than $200 Billion in Stashed Russian Cash

Sanctions
(Bloomberg) — Swiss banks may hold more than $200 billion of Russian wealth, the country’s banking lobby estimates, as sanctions shine a spotlight on the extent of Russian wealth stored in overseas vaults. Banks probably hold between 150 billion ($160 billion) and 200 billion Swiss francs of Russian client money in offshore accounts, according to the Swiss Bankers Association. Credit Suisse Group AG Chief Executive Officer Thomas Gottstein said earlier this week that Russian money accounted for about 4% of assets at the bank’s wealth management division. The country of 8.6 million inhabitants has long been attractive for wealthy Russians,…

New Financial Sanctions Measures in Relation to Russia

Sanctions
Following the Prime Minister’s statement to the House of Commons on 22 February 2022, the UK announced a tranche of sanctions on Russia. The Prime Minister announced further measures on 24 February 2022 which are available on the Foreign, Commonwealth & Development Office website. If you require a licence to permit any activity which would otherwise be prohibited by sanctions regulations, you must contact the relevant department. We expect firms to have established systems and controls to counter the risk that they might be used to further financial crime and this includes compliance with financial sanctions obligations. Where the FCA…

First U.K. Annual Sanctions Report

Sanctions
The UK’s Annual Sanctions Report for 2021 details, for the first time, the full extent of its new autonomous sanctions since exiting the European Union. the Foreign, Commonwealth & Development Office Sanctions Annual Report for 2021 has been published, which shows that, in its first full year since leaving the EU, the UK has imposed sanctions against 160 individuals and entities individuals and entities sanctioned for, among other activities, corruption and human rights abuses, are from a number of countries, including Myanmar, China, Belarus, Pakistan and Venezuela the report shows that since leaving the EU, the UK is more agile…

U.S. Sanctions Bosnian Serb Leader over Graft and for Destabilizing Moves

Sanctions
The U.S. sanctioned on Wednesday the leader of the Bosnian Serbs and a TV station believed to be under his control for his “corrupt activities and continued threats to the stability and territorial integrity” of the Balkan country. Milorad Dodik, who is the Serb member of Bosnia and Herzegovina’s tripartite presidency, has frequently called for the dissolution of the country and has recently initiated a process of a gradual transfer of authorities from the state to the Bosnian Serb region called Republika Srpska, which occupies half of Bosnia and Herzegovina. He intends to withdraw the Serbs from the country’s army,…

As U.S. Sanctions Loomed, a Tycoon Mopped Up Zimbabwe’s Scarce Dollars

Corruption, Sanctions
As Zimbabweans faced the economic consequences of a crashing currency, well-connected businessman Kudakwashe Tagwirei skirted the rules to convert government-backed securities into scarce U.S. dollars —which he used to acquire shares in a lucrative platinum mine. Key Findings Even after Zimbabwe cut off its citizens from accessing U.S. dollars in mid-2019, the central bank governor allowed Tagwirei’s company to cash out large portions of a treasury bill he held before it matured, and unlawfully convert them into tens of millions of U.S. dollars. Documents indicate Tagwirei’s staff repeatedly used treasury bills as a source of U.S. dollars — which were…

EU Imposes Restrictive Measures Against the Wagner Group

Sanctions
The Council today adopted a set of restrictive measures against the Wagner Group, a Russia-based unincorporated private military entity. The measures target the Wagner group itself, and eight individuals and three entities connected to it. The Wagner Group has recruited, trained and sent private military operatives to conflict zones around the world to fuel violence, loot natural resources and intimidate civilians in violation of international law, including international human rights law. The individuals listed by the EU are involved in serious human rights abuses, including torture and extrajudicial, summary or arbitrary executions and killings, or in destabilising activities in some…

U.S. Designates Serbian, Salvadoran Gangs with Political Ties

Bribery, Corruption, Sanctions
The U.S. authorities announced Wednesday they have targeted 16 individuals and 24 entities suspected of corruption and serious human rights abuses. The ruling freezes U.S. property and money connected to those people and entities. The Office of Foreign Assets Control (OFAC) took the actions “pursuant to Executive Order 13818, which builds upon and implements the Global Magnitsky Human Rights Accountability Act,” according to the U.S. Treasury Department’s statement. “All property and interests in property of the persons above that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to…

U.S. Expands Sanctions on Belarus Over Migrant Crisis

Sanctions
The U.S. Treasury Department tightened the screws on Belarussian strongman Alexander Lukashenko and his allies, according to a statement released Thursday. Treasury officials listed 20 individuals, 12 entities and three aircraft as “blocked property” in the United States. They said the move was “in response to the Lukashenko regime’s blatant disregard for international norms and the well-being of its own citizens.” The sanctions come amid a widening migrant crisis unfolding on Belarus’s border with Poland and Lithuania — both members of the European Union. Tens of thousands of immigrants, primarily from Iraqi Kurdistan, have gathered in the eastern European nation,…

Notorious Money Launderer Reza Zarrab’s Lavish Life and New Business in Miami

Money Laundering, Organised Crime, Sanctions
Facing 130 years in prison, infamous Turkish-Iranian money launderer Reza Zarrab took a plea deal in 2017 agreeing to testify in U.S. courts. Federal officials have since kept him out of the spotlight, while allowing him to live a government-sanctioned life of luxury under a false identity in Miami. But the man who made his fortune cleaning profits from sanctions evasion and dealing with companies tied to slave labor and organized crime has been anything but idle. An investigation by OCCRP, Law&Crime and the Miami Herald found that Zarrab remains connected to his former criminal network and has received multiple…

U.S. Imposes Further Sanctions in Connection With Nord Stream 2 Gas Pipeline

Sanctions
The Nord Stream 2 gas pipeline, Secretary of State Antony Blinken said in a statement, targeting Russia-linked Transadria Ltd. and its vessel. The State Department submitted a report to the U.S. Congress listing two vessels and an entity, Transadria Ltd., involved in the pipeline, Blinken said, but did not give details on the second vessel. Washington opposes the $11 billion pipeline, which runs under the Baltic Sea to bypass Ukraine and carry gas from Russia’s Arctic region to Germany. Nord Stream 2 has faced stiff opposition from the United States and some European states, which say it will make Europe…

Ex-Prison Warden in Lithuania Struck $1M Deal with Sanctioned Belarusian State Truckmaker

Sanctions
A former prison warden from Lithuania may have helped the regime of Belarusian dictator Alexander Lukashenko dodge sanctions by benefitting from a $1.1 million deal to export Belarusian trucks through Lithuania’s biggest seaport. The trucks in question were made by sanctioned Belrussian state company BelAZ, one of the world’s top manufacturers of large trucks and dump trucks, and a major source of income for Lukashenko’s regime. The European Union sanctioned BelAZ in June 2021 in the midst of a violent crackdown by Lukashenko on civil society, journalists, and opponents in the wake of a disputed election. Since then, EU businesses…

Crypto Exchange Chatex and Russian Nationals Indicted for Roles in Ransomware Operations

Digital Currencies, Sanctions
Today, the Department of Justice (DOJ) and U.S. Treasury’s Office of Foreign Asset Control (OFAC) announced joint indictments, arrests, and sanctions designations against organizations and individuals associated with ransomware attacks against U.S. companies. Telegram bot-based P2P cryptocurrency exchange Chatex, which shares a founder with recently sanctioned OTC service Suex, has now been added to the Specially Designated Nationals and Blocked Persons (SDN) List, thereby prohibiting Americans from doing business with the company. Additionally, three other companies were sanctioned for their role in setting up key infrastructure Chatex relied on to operate. It’s important to remember that unlike violations of anti-money…

Everything You Need to Know About OFAC’s New Sanctions Guidance for Cryptocurrency Businesses

Digital Currencies, Sanctions
On October 15, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) released Sanctions Compliance Guidance for the Virtual Currency Industry. This guidance follows the recent designation of Russia-based cryptocurrency Over The Counter (OTC) broker Suex, as well as an updated Advisory on ransomware payments, which we wrote about in our blog. The newly-released brochure reiterates OFAC’s previous guidance and outlines best practices in one comprehensive document. Specifically, OFAC’s guidance covers: Sanctions-related compliance requirements for cryptocurrency businesses Consequences for non-compliance and examples of how timely reporting can mitigate those consequences Best practices for building a risk-based compliance…

U.S. Sanctions Two Lebanese Businessmen and a Member of Parliament

Sanctions
The U.S. Treasury has imposed sanctions on two top Lebanese contractors and a lawmaker close to the Hezbollah movement over alleged large-scale corruption that undermined the rule of law in Lebanon. Businessmen Jihad al-Arab and Dany Khoury, close to former Lebanese Prime Minister Saad al-Hariri and Christian politician Gebran Bassil respectively, were sanctioned on Thursday for alleged corruption related to state contracts. Lawmaker Jamil Sayyed was sanctioned for allegedly seeking to “skirt domestic banking policies and regulations” and transfer $120 million abroad, “presumably to enrich himself and his associates,” a Treasury statement said. The allegations come amid an unprecedented economic…

Ethereum Researcher Virgil Griffith Pleads Guilty to Helping North Korea Dodge US Sanctions

Sanctions
Virgil Griffith, an Ethereum Foundation researcher, pleaded guilty to aiding North Korea in sidestepping US sanctions using blockchain technology, according to a Bloomberg report. Griffith was arrested in 2019 after he attended a Pyongyang blockchain conference. US authorities alleged that he helped the North Koreans deploy blockchain tech to let the country sidestep strict international sanctions. Prosecutors say his presentation was tantamount to giving services to North Korea and his trip was not approved by America, according to the Wall Street Journal. Griffith’s lawyers countered that he gave out simple information available easily online. The trial was set to begin…

U.S. Sanction Crypto Exchange over Ransomware Attacks

Digital Currencies, Sanctions
For the first time ever, U.S. authorities imposed sanctions against a virtual currency exchange for its role in facilitating financial transactions for ransomware actors, the Department of the Treasury’s Office of Foreign Assets Control (OFAC), said in a statement Tuesday. “All property and interests in property of the designated target that are subject to U.S. jurisdiction are blocked, and U.S. persons are generally prohibited from engaging in transactions with them,” read the statement. OFAC claims that SUEX OTC enabled transactions involving at least eight ransomware variants’ illegal proceeds, and that a study revealed that illicit actors were involved in more…

Behind Suex.io: the first sanctioned cryptocurrency exchange

Digital Currencies, Sanctions
This morning, OFAC sanctioned SUEX.io, a concierge cryptocurrency exchanger incorporated in Czechia but operating in Russia. This action comes as OFAC and the US Government writ-large try to tackle the festering problems posed by ransomware, and the criminal syndicates using it to extort billions of dollars out of victims around the world. SUEX filled an essential niche in the ecosystem of underregulated exchanges that, either through willful ignorance or witting cooperation, facilitate the conversion of illicit crypto ransoms into real-world currency. SUEX largely communicated with its clients on the Telegram app and accepted new customers on a system of referrals…

China’s Planned Anti-Sanctions Law for Hong Kong Unsettles Financial Sector

Sanctions
Global banks and other financial institutions in Hong Kong are scrambling to find out details of China’s planned imposition of an anti-sanctions law on the city, and trying to understand how it could impact their operations in the financial hub. Beijing adopted a law in June under which individuals or entities involved in making or implementing discriminatory measures against Chinese citizens or entities could be put on a government anti-sanctions list. Financial firms are closely watching a meeting this week of the National People’s Congress Standing Committee, the highest organ of China’s parliament, for signs on how and when similar…

UK/US Impose Sanctions on Russian Intelligence Agents Over Navalny Poisoning

Sanctions
Britain and the United States imposed sanctions on Friday on men they said were Russian intelligence operatives responsible for the poisoning one year ago of Kremlin critic Alexei Navalny. The two countries both targeted seven Russians with sanctions and also issued a joint statement warning Russia over chemical weapons. Washington separately imposed sanctions on another two men and four Russian institutes it said were involved in chemical weapons research or what it described as an assassination attempt against Navalny. Navalny was flown to Germany for medical treatment after being poisoned in Siberia on Aug. 20 last year with what Western…

Active Shipping Companies Linked to Oil Smuggling and Sanctioned Terror Financiers

Sanctions, Terrorism
On Jun. 10, 2021 the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) designated a group of individuals and companies as Specially Designated Global Terrorists (SDGT). The designation is due to the group’s role in smuggling petrochemicals for Iran’s Revolutionary Guard Corps – Qods Force (IRGC-QF) and using the proceeds to finance Houthi rebels in Yemen. Using public records, we found multiple active companies linked to this network in the Middle East, Europe, and Latin America. These general trading and shipping companies, which remain unsanctioned, pose a risk to individuals or companies that might unknowingly do business with them,…

FinCEN Announces New Acting Director

Sanctions, Terrorism
WASHINGTON—Financial Crimes Enforcement Network (FinCEN) Acting Director Michael Mosier today announced he will depart FinCEN at the end of the week for a new opportunity, after serving as the organization’s acting director. Himamauli “Him” Das, a national security expert with experience at the White House, National Security Council, National Economic Council, and Departments of State and the Treasury, will assume the role of acting director of FinCEN. Today, Treasury launched a public search for a permanent FinCEN director. “It is an honor to be returning to the Department of the Treasury as acting director of FinCEN to continue the important…

Sanctions Fine for U.K. FinTech

Sanctions
Over a period of around 21 months up to 18 December 2019, TransferGo facilitated a series of 16 payments to accounts held at the Russian National Commercial Bank (RNCB). During that period, the RNCB was subject to EU sanctions imposed in relation to Russia’s annexation of Crimea. The EU’s sanctions regulations applied directly in the UK during that time as it preceded the end of the Brexit transition period. RNCB remains a sanctions target under the UK sanctions regime, which now operates distinctly from the EU sanctions framework. According to the OFSI, TransferGo had claimed that because “the relevant clients…

Equatorial Guinea to Close Embassy After U.K. Sanctioned President’s Son

Sanctions
In protest of the United Kingdom’s decision to put the son of President Teodoro Obiang Mangue on the latest list of individuals sanctioned for corruption, Equatorial Guinea said on Monday it will close its embassy in London. The U.K. last Thursday announced new sanctions against five individuals from Equatorial Guinea, Zimbabwe, Venezuela and Iraq for their involvement in “serious corruption” that has deprived citizens in these countries of “vital resources.” The announcement marks the second round of designations under the U.K.’s Global Anti-Corruption sanctions regime inaugurated in April when 22 individuals were targeted with asset freezes and travel bans. The…

Unseen and Unsanctioned, Belarusian Tycoon Slipped into the EU via Lithuanian Investments

Sanctions
Alexei Aleksin and Alexander Zaytsev have emerged as two of the wealthiest businessmen in Belarus. What are they doing in Lithuania? Key Findings Aleksin and Zaytsev began to receive generous economic preferences from dictator Alexander Lukashenko in the aftermath of 2012 sanctions against his regime. Around the same time, they managed to obtain Lithuanian residency permits and opened companies there. The nature of their activities in Lithuania raise serious questions about what they are doing in the EU member state. Aleksin registered a company in an abandoned building, then used it to buy an apartment where two more firms are…

New U.K. Sanctions Against Individuals Involved in Corruption Around the World

Corruption, Sanctions
Foreign Secretary Dominic Raab has announced further sanctions on individuals under the UK’s Global Anti-Corruption sanctions regime. Foreign Secretary Dominic Raab today announces new UK sanctions against 5 individuals involved in serious corruption in Equatorial Guinea, Zimbabwe, Venezuela and Iraq sanctions target cases of serious corruption which have deprived developing countries of vital resources one of those designated spent millions of misappropriated funds on mansions, private jets and a $275,000 glove that Michael Jackson wore on his ‘Bad’ tour, another ruthlessly exploited public food programmes in Venezuela. Foreign Secretary Dominic Raab has today announced further sanctions on individuals under the…

Russian oligarchs the ‘most sophisticated in the world’ at dodging KYC and evading sanctions

KYC, Sanctions
THE CAPACITY OF Russian oligarchs to work around rigorous KYC rules and international sanctions is the strongest in the world, a former FATF President has warned. Their methods were so capable that their identity may remain hidden even if a financial institution makes every effort to root out accurate beneficial ownership information, he suggested. In the same speech, he also hit out at the Russian FIU Rosfinmonitoring claiming that it was “firmly under the control” of the country’s Federal Security Service (FSB) and headed by a sixteen-year veteran of the Soviet KGB. Billingslea believes the FIU allows state-sponsored money-laundering schemes…

Biden-Harris administration: 100-day review of Sanctions policy

Sanctions
When the Biden administration took office on 20 January 2021 it had already announced that there would be reviews of how the US deals with international partnerships. Under the previous administration the US had left the Paris accord on climate change and the World Health Organisation (WHO). Within a day of taking office the new administration set in motion the reversal of both the withdrawal from the Paris agreement and WHO membership. US secretary of the treasury Janet Yellen has said that one of her top priorities is to review the US use of sanctions as well as those that…

New Magnitsky style sanctions regime will strengthen Britain’s toolkit for tacking global corruption and dirty money

Corruption, Sanctions
Transparency International UK welcomes the announcement of a new corruption sanctions regime by Foreign Secretary Dominic Raab. The new regime gives Britain the power to designate individuals and companies involved in serious corruption around the world, adding another option to the UK’s growing array of sanctions for corruption offences. The UK Government has published an initial list of 22 designated persons who are the first targets of the regime. Those that are designated will have their British assets frozen and be banned from travelling to the UK. The regime is international in scope, enabling the UK to align itself with…