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OTC’s Business Crime and Regulation Team instructed in one of the first UK Sanctions Framework cases


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Alex Haines and Sophie O’Sullivan have been instructed by a US-based law firm to represent an Eastern European engineering firm in relation to its sanctions designation under UK legislation and regulation. This is one of the first sanctions challenges to operate within the UK’s new and autonomous statutory framework.

From 1st January 2021, the UK was no longer required to implement EU sanctions and the new UK sanctions legislation officially came into force under the Sanctions and Anti-Money Laundering Act 2018 (SAMLA).

SAMLA provides the UK with a domestic statutory framework of powers, which enable it to continue to meet its international obligations under the UN Charter to implement UN sanctions law directly in the UK. Put simply, SAMLA fills the legislative gap created by the UK leaving the EU and provides the UK with a new sanctions framework within which to operate.

At the end of 2020, a number of entities previously designated under the EU sanctions framework were co-designated by the UK Sanctions List of HM Treasury Office of Financial Sanctions Implementation (OFSI) under SAMLA and specific EU Exit Regulations.

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Alex – admitted to the English, New York and Irish Bars – specialises in International Organisations Law, Commercial Crime (including global investigations) and Sanctions Law. He was appointed to the Attorney General’s London B Panel of Counsel to the Crown in 2019 and he co-authored the new chapter on UK, UN and EU Sanctions in Smith, Owen, and Bodnar on Asset Recovery (Criminal Confiscation and Civil Recovery) for OUP in 2019. In 2020 he authored the new chapter on the Sanctions Regimes of Multilateral Development Banks in Lissack and Horlick on Bribery and Corruption (3rd Ed.) for Lexis Nexis. Alex was appointed as Sanctions Officer at the Caribbean Development Bank in 2020 and he is currently instructed to undertake an internal investigation for a UN specialised agency headquartered in Geneva.

Sophie specialises in Commercial Crime, Financial Regulation, Asset Forfeiture & Civil Recovery and Sanctions Law. She conducts contentious work, appearing in crown and appellate courts, in addition to her advisory practice. She is a Leading Junior in the Legal 500’s Financial Crime sector and contributed to the 3rd edition of Lissack and Horlick on Bribery and Corruption (3rd Ed.), the leading work on bribery and corruption offences. Sophie is appointed to the Attorney General’s Panel of Counsel to the Crown and the Serious Fraud Office’s Proceeds of Crime Panel of Counsel.

To find out more about Alex, Sophie or our Business Crime Team, please contact Colin Bunyan on +44 (0)20 7427 4886 for a confidential discussion.


Barristers: Alex Haines | Sophie O'Sullivan
Categories: News | Business Crime