LLC Synesis’s Unsuccessful Delisting Application (March 2023):
A pertinent example is the case of LLC Synesis, a Belarusian technology company that developed surveillance software capable of using CCTV to track people and vehicles. Synesis challenged its designation under the UK’s sanctions regime, applying for a ministerial review, which was upheld by the Secretary of State. Synesis then initiated a court review, marking the first judicial review of a sanctions listing under the Sanctions and Anti-Money Laundering Act The English court upheld the designation, demonstrating the challenges entities face in contesting sanctions. The court’s decision highlighted the broad discretion granted to the Secretary of State in assessing information and making designation decisions.