Sanctions Tracker: UK Round-Up

UK sanctions enforcement strategy

The UK government has published a paper on its strategic approach to sanctions enforcement, noting that robust sanctions enforcement is a priority. The paper explains which bodies are responsible for civil and criminal enforcement of different types of sanctions, and provides an overview of the UK licensing and breach reporting framework.

The paper explains that the approach to sanctions enforcement is guided by four principles: (i) driving compliance, (ii) proportionality and fairness, (iii) transparency, and (iv) due process.

The paper also explains the different types of civil enforcement action which may be taken, and the mitigating and aggravating factors that will typically form part of the case assessment.

OTSI expands licensing remit

From 27 April, the Office of Trade Sanctions Implementation ("OTSI") will take on expanded trade licensing powers. OTSI is currently responsible for licensing the provision of restricted services (in particular under Russia professional business services sanctions), but will become responsible for licences involving sanctioned goods and associated ancillary services, with the exception of goods which are subject to strategic export controls. Goods falling into the latter category will remain the responsibility of the Export Control Joint Unit (the "ECJU").

Further guidance will be published ahead of 27 April but, in the meantime, OTSI has published a blog with further information. Companies should note in particular that any applications which are required to be made to OTSI from this date onwards should be made via the SPIRE system. This system is also used by the ECJU, meaning that applications relating to goods which are subject to both sanctions and strategic export controls will also continue to be dealt with via SPIRE in the usual way.

Guidance on licensing

A range of further licensing resources have been published in recent weeks, as summarised below.

• The Office of Financial Sanctions Implementation ("OFSI") has published a blog to update on its approach to reasonableness in licensing decisions. This sets out the supporting information and evidence requested by OFSI in order to assess certain licence applications (in particular in respect of legal services and the maintenance of frozen funds and economic resources).
• The UK government has published new guidance on the availability of licensing and exemptions (covering both financial and trade sanctions). 
• In relation to Belarus specifically, the Department for Business and Trade has provided a look-up guide on the considerations for drafting trade licences for different types of goods.

OFSI ten-year anniversary

This year marks ten years since the establishment of OFSI. OFSI has published reflections from its director to mark the occasion, emphasising that financial sanctions have become an increasingly important tool in furthering the UK's foreign policy, national security and economic aims.

OFSI has also published a new strategy for the period 2026-29 setting out its plan to ensure that financial sanctions remain "effective, resilient and impactful". We will cover the key takeaways from the strategy in a separate post.

Enhancements to statutory guidance

The UK statutory guidance published in respect of each sanctions regime has been updated to make various enhancements to structure and clarity. In particular, each regime's guidance now contains a summary giving a high level overview of the sanctions in place.

The statutory guidance can be accessed from this page.

Updated guidance on circumvention and sanctions evasion

OTSI's guidance on sanctions evasion has been amended to update the list of UK goods at higher risk of circumvention.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.