Writing in NLJ this week, Paul Henty, partner at Beale & Company Solicitors LLP, says the supposedly 'miscellaneous' amendments are anything but. New 'end-user controls' mean companies can commit criminal offences if they ignore government notifications identifying apparently innocent counterparties as proxies for sanctioned states. The Russia amendments also target 'oil laundering' through third-country refineries, widen restrictions on maritime services and add construction services to prohibited professional services.
Henty warns enforcement is tightening, with larger civil penalties, strict liability and increasing expectations around due diligence. Screening lists alone are no longer enough, he argues. Instead, businesses must exercise 'active vigilance', investigating supply chains, counterparties and regulatory notices if they are to avoid potentially costly enforcement action.
