United Kingdom: Export Controls & Trade & Investment Sanctions

The UK's HMRC has published comprehensive enforcement statistics covering 2025 and early 2026, revealing the scope and outcomes of sanctions enforcement activities including criminal investigations, goods seizures, and penalty assessments. The data provides insight into how authorities are handling sanctions violations through various enforcement mechanisms, from warning letters to compound penalties exceeding £1 million.

A UK court dismissed sanctions charges against art gallery Hauser & Wirth and logistics company Artay Rauchweger, ruling that prosecutors failed to prove the buyer of luxury artwork was "ordinarily resident" in Russia at the time of sale. The judge determined that evidence of continuing connection to Russia was insufficient to meet the statutory test for ordinary residence under UK sanctions regulations.

An Indian national serving as captain of a sanctioned Russian oil tanker faces criminal prosecution in the UK, with his bail application denied and a trial scheduled for December. The court will also hear a motion to dismiss the charges in November, though the legal basis for dismissal remains undisclosed.

On 5 June 2026, the UK’s Financial Conduct Authority (FCA) and HM Treasury’s Office of Financial Sanctions Implementation (OFSI) published a renewed Memorandum of Understanding (the MoU) setting out their arrangements for co-operation and information sharing in relation to UK sanctions.

The UK's HM Revenue and Customs has imposed a substantial compound penalty on Petrofac Facilities Management Limited for breaching Russia sanctions, marking a significant shift in enforcement policy. This case reveals new guidance on when HMRC will pursue compound penalties versus prosecution, and signals a major change in the agency's approach to publicly naming violators. The announcement provides crucial insights into the factors HMRC considers when determining appropriate enforcement actions for strateg

Our latest sanctions tracker update provides an overview of recent UK sanctions developments including the latest financial sanctions enforcement action.

The Financial Conduct Authority has published findings from its review of over 150 firms' sanctions systems and controls, revealing persistent weaknesses in due diligence, alert management, and trade sanctions compliance. While systems have strengthened since 2023, the average time to report breaches remains over 100 days, and firms continue to struggle with detecting sanctions evasion, particularly in payments, retail banking, and wholesale financial markets sectors.

The UK Financial Conduct Authority's May 2026 review of 150 authorized firms reveals that while sanctions compliance has improved since 2022, significant gaps persist in customer due diligence...

The UK government has introduced new sanctions targeting cryptocurrency networks and digital asset services that facilitate sanctions evasion, marking a significant expansion of its Russia sanctions regime. These measures aim to close loopholes exploited by designated persons and entities seeking to circumvent financial restrictions through crypto channels.