“Interesting Times”: Sanctions, Bonds and Litigation
Date: 04 March 2022
There are, as at the date of writing (26 – 31 March 2022), 978 individuals and 98 entities on the Office of Financial Sanctions Implementation (“OFSI”) Consolidated Russia sanctions list (“the Consolidated List”). The list exists under section 43 of the Sanctions and Anti-Money Laundering Act 2018 (‘the Sanctions Act’), the Russia (Sanctions) (EU Exit) Regulations 2019 SI 855 (“the Regulations”) as amended twice in 2020 and six times in 2022 alone. There are two sets of provisions that are particularly relevant to commercial and construction litigators, and then even more specifically, to the financing of large infrastructure or other property developments.
This article by Sean Wilken QC considers those provisions and the current sanctions regime.