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UK Russia Response: New Law Passed Imposing Strict Liability for Financial Sanctions Breaches by Companies

International Trade and Investment Alert™ | March 18, 2022

In response to Russia’s invasion of Ukraine, the UK has rushed through legislation that will make breaches of financial sanctions a strict liability civil offence, punishable by fines of up to £1m (approximately $1.3m) or 50% of the estimated value of the economic resources made available (whichever is the greater). In addition, the UK will have the power to “name and shame” companies found to have breached sanctions, even where no penalty is imposed.

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