Sanctions Limbo – Assessing Ownership & Control | Breakfast Briefing


Raedas hosted an invite-only breakfast briefing at a private members club in London on the 7th December. The get-together provided a unique platform for peer debate on the issues of ownership and control by designated persons in UK sanctions law, in light of the OFSI/FCDO’s Joint Guidance, the Court of Appeal’s judgment in Mints & Ors v PJSC National Bank Trust and the High Court’s judgment in Litasco.

The Joint Guidance reiterates expectations that counterparties will fully consider the risks of an entity being owned or controlled and undertake due diligence to ensure compliance with financial sanctions – a point that was addressed by Raedas in the course of briefing. The discussion took place under the Chatham House Rule. Our audience included representatives of financial, insurance, commodities and other sectors, with the discussion  focusing on practicalities.

Moderator: Michael O’Kane, Senior Partner, Peters & Peters


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