The sentencing at the Royal Courts of Roy Jeanne and Michael Timms for their roles in a multi-million pound fraud are a stark reminder to all firms that internal fraud can happen at any business.

OFSI in the UK has now issued clarificatory guidance in response to a surprising decision by the English Court of Appeal with serious consequences for Jersey businesses subject to the application of Jersey’s sanction’s laws.

The Court of Appeal stated that "in a very real sense (and certainly in the sense of [the applicable regulation], Mr Putin could be deemed to control everything in Russia". This briefing note considers the impact of that decision and the current position post the clarification by OFSI.