WIACON
is your partner who knows the challenges of regulatory compliance and the needs in a dynamic market. With our extensive knowledge and experience, we bridge any gaps between compliance, legal departments, keep top management informed and manage internal and external IT teams, ensuring smooth collaboration and integration of services. We don‘t support siloed approaches, we offer comprehensive advisory services that combine compliance expertise, legal advice, strategic advice and IT implementation. We enable your business in complying with regulations, optimising processes and driving growth. Your path to more success will be based on:
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The imposition of sanctions on Russia has evolved significantly since the first measures were introduced in 2014, after Russian forces annexed Crimea. At that time, the European Union's response was cautious.
Let's start with a brief historical context of Russia's aggression against Ukraine.
Following Russia's annexation of Crimea in 2014 and support for separatists in eastern Ukraine, tensions between Russia and Ukraine escalated. Despite diplomatic efforts such as the Minsk agreements, the conflict in Donbass continued with low intensity.
For more than five decades, the Assad family ruled Syria with an iron hand, shaping the country through authoritarian control, political oppression and systematic human rights violations. From Hafez al-Assad's seizure of power in 1971 to Bashar al-Assad's escape in 2024, the country has now borne the consequences of dictatorship, war and international isolation.
Russia’s persistent efforts to bypass the oil price cap have prompted the European Union to take decisive action in its 15th sanctions package. This new set of measures targets loopholes that have enabled Russia to continue exporting oil and sustaining its revenues. By blacklisting 52 additional vessels—bringing the total to 79—the EU is focusing on Russia’s shadow fleet, a network of aging, underregulated ships central to its evasion strategies. This initiative has the potential to increase the cost and complexity of sanctions evasion while addressing the significant safety and environmental concerns associated with these high-risk vessels.
A valid contract is binding upon the parties. This statement serves as the cornerstone of contract law worldwide. However, it does not imply that there are no situations in which parties can legally terminate, suspend, or refuse to fulfill their contractual obligations for legal reasons. Typically, these reasons can be anticipated ex-ante in applicable law or in the contract itself. How about newly introduced sanctions? Can they provide a green light for parties to refrain from undertaking their contractual obligations?
With the recent adoption of the EU’s 13th sanctions package against Russia, we sought insights from our senior legal officers at Wiacon, Negin Ajam and Nasim Zargarinezhad.
The EU’s decision to sanction Chinese firms, among others, aims to disrupt the supply chain of vital drone components to Russia, especially given the ongoing conflict in Ukraine.
A major catalyst for the creation of dedicated sanctions roles was the first US sanctions legislation, notably the Trading with the Enemy Act (1917) 1and the establishment of the Office of Foreign Assets Control (OFAC) 2in the 1950s. Together, they gave the US government broad powers to administer and enforce economic sanctions motivated by foreign policy. Over time, these measures required individuals or even small teams mainly in the banks to keep track of the ever-changing sanctions lists and ensure that no prohibited parties had access to the financial system.
The European Union will implement a transformative AML framework in July 2025, taking a significant step in the fight against money laundering and terrorist financing. This new package, already adopted in 2024 in response to persistent vulnerabilities in the financial system and the complexity of cross-border risks, offers an ambitious overhaul of the regulatory landscape.
The Risk-Based Approach (RBA) is a foundational principle in modern anti-money laundering (AML) frameworks. It is about understanding the risks of money laundering and terrorist financing (ML/TF) within a business. By identifying and assessing these risks, the RBA supports an effective but also efficient allocation of resources to combat ML/TF effectively.
Identifying suspicious activities is a cornerstone of combating money laundering, helping Obliged Entities (OEs) detect and deter fraud and other illicit activities. To this end, OEs must closely monitor high-risk criteria to flag transactions or behaviours that deviate from standard patterns. All red flags should be investigated to determine whether they represent legitimate transactions or warrant further scrutiny.
The threat of money laundering has become a major problem for financial institutions worldwide. Both banks and non-bank financial institutions, such as insurance or investment companies, are under increasing regulatory pressure to implement effective and efficient anti-money laundering (AML) solutions to prevent illicit financial activities. These institutions must not only protect their business and reputation, but also ensure that they do not become unwitting accomplices of criminal individuals or organisations.
The threat of money laundering has become a major problem for financial institutions worldwide. Both banks and non-bank financial institutions, such as insurance or investment companies, are under increasing regulatory pressure to implement effective and efficient anti-money laundering (AML) solutions to prevent illicit financial activities. These institutions must not only protect their business and reputation, but also ensure that they do not become unwitting accomplices of criminal individuals or organisations.