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This post contains a round-up of recent UK sanctions developments, including a range of new sanctions guidance and sanctions enforcement updates.
New designations
In coordination with the US and Australia, the UK has imposed sanctions targeting a Russian cybercrime group under the UK's Russia and Cyber sanctions regimes.
Sanctions enforcement news
HMRC has announced a compound settlement of over £1.1m with a UK exporter that made goods available to Russia in breach of the current UK trade sanctions. This is the largest compound settlement HMRC has concluded for a Russia sanctions offence. Although only very limited details about the exporter's conduct are available, HMRC has flagged certain "key compliance lessons", including the importance of due diligence on the end user of goods being exported to Central Asia and other regions where Russian companies have operations.
In other sanctions enforcement news, the National Crime Agency ("NCA") has published an update on "Operation Destabilise", an international NCA-led investigation into Russian money laundering networks (discussed in our previous post), identifying that a particular network purchased a bank in Kyrgyzstan to facilitate sanctions evasion. The second phase of the operation has involved a further 45 arrests, and the seizure of over £5m in cash.
New sanctions guidance
Recent weeks have seen a range of new sanctions guidance published in the UK. These include a single page on sanctions enforcement action (covering actions by the Office of Financial Sanctions Implementation ("OFSI"), the Office of Trade Sanctions Implementation ("OTSI"), the NCA and others).
From a compliance perspective, OTSI has published new guidance for the freight and shipping sectors on countering sanctions evasion and the NCA has issued an amber alert in relation to the "shadow fleets" enabling sanctions circumvention, including providing information on commonly seen typologies.
Finally, OFSI has made a number of amendments to its financial sanctions FAQs. These include the withdrawal of certain FAQs (7, 9 54 and 76 – which can now be found here), and the addition of new FAQs 170-174.
General licences
OFSI has issued two new general licences ("GLs"):
Both GLs relate to the continuation of business with entities in the Lukoil group: respectively Lukoil entities in Bulgaria, and Lukoil International GmbH and its subsidiaries. Both GLs expire in February 2026.
For further commentary on the US sanctions implications of Lukoil's designation (and the availability of US GLs), please see this post.
Litigation update
This recent post from our Banking Litigation colleagues considers a decision on the interaction between sanctions compliance and equality law.
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.
