STEPTOE: OUTSIDE COUNSEL
Following Russia’s invasion of Ukraine in February 2022 and the significant expansion of sanctions targeting Russia that has followed, the sustained focus of governments, sanctions agencies, and businesses in 2023 has been on stymying efforts to circumvent and undermine those sanctions through evasion. The publication by the National Economic Crime Centre (“NECC”) in the UK’s National Crime Agency (“NCA”) of a Red Alert on Gold-based Financial and Trade Sanctions Circumv...
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