Zulfi Meerza and Aziz Rahman analyse the likelihood of prosecutions for sanctions-related offences

With the National Crime Agency having announced it had arrested 10 people it suspected of helping “corrupt elites’’ avoid sanctions, Aziz Rahman and Zulfi Meerza wrote about the prospect of criminal prosecutions for such wrongdoing.

In their article, which was published by Money Laundering Bulletin, they explain the recent developments that may affect the chances of sanctions prosecutions. These include the NCA’s setting up of a Combating Kleptocracy Cell to disrupt and investigate the activities of corrupt elites and the Red Alert on financial sanctions evasion typologies issued by the National Economic Crime Centre (NECC) and the Office of Financial Sanctions Implementation (OFSI).

The piece summarises the relevant legislation and outlines some of the business sectors that may come under close scrutiny for enabling sanctions evasion.

Zulfi and Aziz say that the Office of Financial Sanctions Implementation (OFSI) may be tempted to dispose of financial sanctions breaches committed after 15 June 2022 by imposing civil monetary penalties on a strict liability basis, through powers introduced via the Economic Crime (Transparency and Enforcement) Act 2022. This may become an increasingly attractive option now the government has talked about a possible 40% reduction in civil service staffing over the next three years.

You can read Zulfi and Aziz's article here. (Subscription required)