United Kingdom: Export Controls & Trade & Investment Sanctions

HM Revenue and Customs has issued its largest sanctions-related compound penalty to date, fining Illumina Cambridge Limited over £7.4 million for breaches of UK Russian sanctions. The company was penalized for its involvement in the supply of sanctioned goods between overseas companies within its corporate group for export to Russia and other destinations between July 2022 and January 2023.

European and UK authorities are dramatically escalating sanctions enforcement against Russia-related violations, marking an unprecedented shift from policy development to aggressive prosecution. Recent actions span criminal convictions with multi-year prison sentences, substantial asset seizures, maritime interdictions of shadow fleet vessels, and penalties targeting both physical goods and digital infrastructure networks.

This weekly update examines recent UK sanctions enforcement actions, including a major alert on the A7 sanctions evasion network, OFSI's penalty against Citibank for Russia sanctions breaches, and the NCA's settlement with an agricultural trading company linked to suspected money laundering. The update also covers new strategic export control statistics and OTSI's annual review revealing 178 reports of potential trade sanctions breaches.

TikTok Information Technologies UK Limited has self-reported potential sanctions breaches to UK and Irish regulators, including the Office of Financial Sanctions Implementation and the Central Bank of Ireland.

British American Tobacco's $1.1 billion settlement with US authorities over North Korean sanctions violations appeared to close one chapter, but opened another as the company now faces multibillion-pound shareholder litigation in London and terrorism-related civil claims. This case illustrates how multinational corporations must carefully navigate the collateral consequences of government enforcement resolutions, as admissions made to one jurisdiction can fuel derivative litigation across multiple forums an

The UK government has significantly expanded its sanctions framework targeting Russia, introducing measures against individuals and entities involved in military supply chains, energy sectors, cryptocurrency networks, and alleged human rights violations. These developments reflect an evolving enforcement landscape with new powers, increased scrutiny of sanctions evasion, and landmark legal clarifications affecting businesses operating in sanctioned jurisdictions.

ESMA has published its 2025 Report on Quality and Use of Data (“Report”), the 6th edition of its annual review across the regulatory reporting regimes within ESMA’s remit.

This comprehensive round-up examines the latest developments in UK, EU, and U.S. sanctions and export controls, covering new designations, enforcement actions, licensing updates, and policy shifts. The analysis explores how sanctions regimes are evolving to address evasion networks, cryptocurrency use, and compliance challenges across multiple jurisdictions.

HMRC has taken the unprecedented step of publicly naming Petrofac Facilities Management Limited after the company paid a compound settlement of £569,157.07 for Russia sanctions violations. Meanwhile, OFSI has released responses to its call for evidence on ownership and control tests, revealing significant practical challenges and costs faced by businesses in making compliance assessments with limited information.