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On February 21, 2022, the White House issued a new Executive Order that imposes comprehensive sanctions on the so-called Donetsk People’s Republic (“DNR”) and Luhansk People’s Republic (“LNR”) regions of Ukraine. Concurrently with the issuance of the Executive Order, the US Treasury Department’s Office of Foreign Assets Control published six general licenses authorizing certain transactions involving the targeted regions. These sanctions were imposed in response to the Russian Government’s decision to recognize the DNR and LNR as independent from Ukraine on the same day.

On 21 February, the UK Office of Financial Sanctions Implementation (“OFSI“), announced that it had issued a monetary penalty totaling GBP 36,393.45 to Clear Junction Limited, a provider of payment services. This penalty follows (and is associated with) OFSI’s earlier GBP 50,000 penalty against TransferGo, announced in August 2021.

The Government closed the Tier 1 Investor visa route to all new applicants with immediate effect on Thursday 17 February. The reason for this is stated to be as a result of security concerns with a number of cases being linked to corruption and illegitimately acquired wealth. The Innovator route is to be restructured in order to provide an investment route which effectively supports the UK’s economy.

On 10 February 2022, the UK Government published amendments to its Russian sanctions programme, enabling it to designate a wide variety of parties “involved in […] obtaining a benefit from or supporting the Government of Russia“. No new designations have been made at this time, but the UK Government has previously indicated that the powers are intended to be used in response to any Russian incursion into Ukraine. The amendment came into force at 5pm UK time on 10 February 2022.

The Office of Financial Sanctions Implementation published an update to the monetary penalties for breaches of financial sanctions guidance on 28 January 2022. The guidance sets out how OFSI will decide when to use its civil enforcement powers to impose monetary penalties for breaches of financial sanctions, and how such penalties will be calculated.