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Jurisdictional Updates 5-24-2022

U.S. Federal – OFAC Taking Action Against Russia
The United States Department of Treasury Office of Foreign Assets Control (OFAC) is taking action to cut off access to services that are used by the Russian Federation and Russian Nationals to evade sanctions. OFAC has identified accounting, trust and corporate formation, and management consulting as categories of services that are subject to a prohibition on the export, reexport, sale, or supply, directly or indirectly, from the United States, or by a U.S. person, wherever located, to any person located in the Russian Federation, pursuant to Executive Order (E.O.) 14071.A link to the full press release and more information on compliance is available at

United Kingdom – New Requirements for Companies Issued by the Financial Conduct Authority
The Financial Conduct Authority (FCA) installed a new requirement for closed-ended investment funds and sovereign-controlled companies. Open-ended investment companies, shell companies or issuers of listed debt and debt-like securities, securitized derivatives or miscellaneous securities are not required to follow the new obligation. Required companies must state in their annual reports if they have met the boar diversity targets, when they plan to or why they have not yet done so starting 1 April 2022. The targets are:

  • The board consists of at least 40 percent women.
  • At least one of the senior board positions (Chair, Chief Executive Officer (CEO), Senior Independent Director (SID) or Chief Financial Officer (CFO)) is held by a woman.
  • At least one member of the board is from a minority ethnic background.