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This edition highlights key developments in UK and international sanctions and export controls, including enforcement reforms, new designations, and emerging compliance risks.
- Enforcement reforms: Office of Financial Sanctions Implementation (OFSI) proposes changes to its enforcement framework, including discounts for voluntary cooperation, and streamlining enforcement of information and reporting offences.
- Cyber sanctions investigations: Media reports indicate OFSI is investigating the UK's first suspected breaches of cyber sanctions, all involving financial services firms.
- UK sanctions policy: All UK designations have been consolidated into a single UK Sanctions List, now the sole authoritative source, supported by a new user guide.
- New and revoked designations: The UK imposed new sanctions under the Iran and Sudan regimes for alleged human rights and humanitarian law violations, and revoked one designation under the Russia regime.
- General Licence updates: Amendments and extensions were made to licences covering revenue authority payments, humanitarian assistance, and the continuation of business for Lukoil Bulgaria entities.
- Compliance guidance: OFSI clarified reporting expectations for refused business, while the Solicitors Regulation Authority updated its sanctions guidance for regulated firms.
- Sanctions trends and scrutiny: Ongoing debate and media reporting highlight potential further sanctions on Russian oil supply chains, and the use of alternative payment networks to bypass sanctions.
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