All goods in the Common High Priority List are under trade sanction, meaning handling them is like handling stolen goods. Companies across the supply chain, from logistics to warehouses to shipping, could be breaking the law if they end up involved with these goods that later end up used by Russia, or in fact any sanctioned country.

There are a number of red flags to be aware of when dealing with sanctioned items, and where there is a risk of a sanctions breach. A single red flag is not necessarily indicative of illicit or suspicious activity. The surrounding facts and circumstances should be considered before determining next steps, like submitting a suspicious activity report to the NCA.

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Download your free guide to the latest developments in sanctions on Russia and what your firm needs to do to stay compliant

The field of economic sanctions has been growing increasingly complicated in recent years. The past year was a historic and transformative period for the use of financial sanctions on both the global and UK levels. Western nations launched an unprecedented line of sanctions against Russia and Russian companies, and also against Russia’s ally Belarus, in response to its February 2022 invasion of Ukraine. With the war showing no end in sight, sanctions and penalties for non-compliance are only continuing to ramp up. 

All businesses, both regulated and unregulated, must comply with financial and trade sanctions and companies must be able to prove that they are properly screening for sanctions. Failure to comply with screening requirements can carry stiff penalties reaching into the millions per infraction and remember that there’s strict liability when it comes to sanctions so any sanctions breach, even accidental, is a crime. 

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Download your free guide to every item under Russian trade sanctions

What is the Common High Priority List?

The Common High Priority List has been developed by the UK, US, EU and Japan which includes many items found on the battlefield in Ukraine. All these items are under sanction. The list is divided into four Tiers, each containing particularly sensitive items such as integrated circuits used in Russian weapons systems, as well as mundane items like ball bearings and TV cameras.

There are dozens and dozens of individual items listed on the Common High Priority List. These items should be treated like handling stolen goods. Transporting, selling, buying, shipping or otherwise being connected to the supply of these goods to sanctioned entities is a criminal offence.

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The field of economic sanctions has been growing increasingly complicated in recent years, and the past year was a historic and transformative period for the use of financial sanctions on both the global and UK levels, with Western nations launching an unprecedented line of sanctions against Russia as a result of its invasion of Ukraine in February 2022.

Recent conflicts such as the Hamas-Israel war in response to Hamas’s October 7th massacre, the Russian invasion of Ukraine, as well as events in Iran, China and other countries have grabbed global headlines. These events have sparked waves of new laws and regulations around the world, from sanctions to tougher economic crime compliance rules.

All businesses must comply with financial and trade sanctions and companies must be able to prove that they are properly screening for sanctions. Failure to comply with screening requirements can carry stiff penalties reaching into the millions per infraction and any sanctions breach, even accidental, is a crime.

This webinar covered:

  • Recent sanctions issues and key compliance challenges and lessons to be aware of in the present volatile international landscape.
  • The creation of the Office of Trade Sanctions Implementation (OTSI), the UK’s newly created body that will be responsible for the civil enforcement of trade sanctions, including those against Russia.
  • The ever-relevant crossover between sanctions, terrorist financing, and AML, which has become increasingly important as the world faces rapidly evolving geopolitical challenges.
  • The effectiveness of financial sanctions in general and those against Russia in the past two years in particular.
  • Cases of sanctions breaches and consequences.
  • Tips for sanctions compliance for both regulated and non-regulated businesses.

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As more Hamas leaders come under international sanction, their relationship with international aid agencies and charities has come under scrutiny. The United Nations Relief and Works Agency for Palestine Refugees in the Near East (UNRWA) is a UN agency that is meant to provide essential services to Palestinians who fled or were displaced during the 1948 War of Independence. With a staff of over 30,000, primarily Palestinians, UNRWA operates in Gaza as well as Jordan, Lebanon, Syria and the West Bank, with a mandate to provide medical care, education, and other social services to vulnerable families and individuals.

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Anti-money laundering audit

Following earlier rounds of US sanctions on Hamas, the US is now offering up to $10 million for information on five Hamas financiers or anything leading to the disruption of the Palestinian terror group’s financial mechanisms, the State Department reported. The five Hamas financial facilitators under this reward offer are named as Abdelbasit Hamza Elhassan Khair, Amer Kamal Sharif Alshawa, Ahmed Sadu Jahleb, Walid Mohammed Mustafa Jadallah, and Muhammad Ahmad ‘Abd Al-Dayim Nasrallah.

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Sign showing Russia closed off due to sanctions

The European Union (EU) recently adopted its 12th package of sanctions against Russia, marking a significant development in response to Russia’s invasion of Ukraine. For companies and businesses operating in the EU, understanding the implications of these sanctions is crucial for maintaining compliance. What’s new in this package, and what does your business need to do to comply? Below are the key elements of the sanctions and some insights on what businesses need to know to comply with these new stricter measures.

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Sanctions stamp

In a significant move, the Japanese government has announced fresh sanctions targeting three senior members of Hamas. Chief Cabinet Secretary Yoshimasa Hayashi revealed on Tuesday that the sanctions would include the freezing of assets and restrictions on payments and capital transactions involving the specified individuals. The decision comes in response to their alleged involvement in the October 7th attacks by Hamas on Israel, with concerns about their ability to use funds to finance further terrorist activities. The government believes that these individuals hold positions enabling them to utilise funds for supporting terrorist activities. 

Meanwhile, just a few days later, the US Treasury Department imposed sanctions on individuals and groups accused of facilitating the flow of Iranian financial assistance to Houthi rebels in Yemen. These sanctions target key figures such as the head of the Currency Exchangers Association in Sana’a, Nabil Al-Hadha, and three exchange houses in Yemen and Turkey. These actions come in response to the Houthi rebels’ targeting of Israel and international shipping lanes since October 7. The measures, blocking access to US property and bank accounts, are part of a broader strategy to curb the illicit flow of funds to the Houthis, who have been conducting dangerous attacks on international shipping, further destabilising the region. The US, along with its allies, emphasises its commitment to targeting facilitation networks supporting the Houthis and their backers in Iran.

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UK government continues laser focus on Russia sanctions with new regulator

The success of the Office of Financial Sanctions (OFSI) on cracking down on sanctions breaches by companies has sparked the creation of a new body, due in early 2024. Similar to the operation of the OFSI, the new Office of Trade Sanctions Implementation will have investigatory powers, will be able to issue civil penalties for strict liability breaches, and refer cases for criminal prosecution.

Currently, the implementation of trade sanctions falls under the jurisdiction of the Export Control Joint Unit (ECJU), which undertakes enforcement action mainly around military and dual use items.

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This Red Alert is published by the UK government and issued by the National Economic Crime Centre (NECC), a multi-agency unit in the National Crime Agency (NCA), HM Treasury’s Office of Financial Sanctions Implementation (OFSI) and the Foreign, Commonwealth & Development Office (FCDO). 

Who is this alert for?

✅Banks

✅Credit card operators

✅Foreign exchange dealers

✅Non-bank payment service providers

✅Customs brokers

✅Freight forwarders

✅Transportation and logistics providers

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