UK Weekly Sanctions Update - Week Of December 15, 2025

In this weekly update, we summarise the most notable updates in the UK sanctions world. If you have any questions in respect of any of the developments set out below, please do not hesitate to contact a member of our London Global and Government Trade team listed above.

Russia Sanctions

• UK Government adds 25 entries to the UK sanctions list under the Russian regime: On December 19, 2025, OFSI added one entry to the UK sanctions list under the Russia regime and on December 18, 2025, OFSI added 24 entries to the UK sanctions list under the Russia regime. These individuals and entities are subject to an asset freeze. (Notice_Russia_191225.pdf; Notice_Russia_181225.pdf; Russia financial sanctions: list of asset-freeze targets - GOV.UK)
• OFSI issues General Licence for the winding down of Russian oil companies: On December 18, 2025, OFSI issued General Licence INT/2025/8202932 which authorises persons to wind down from any transactions involving the designated persons to which that person is a party, subject to terms and conditions. This General Licence expires on 31 January 2026. (GL_Document_-_Russian_Oil_Companies_Dec_2025.pdf; OFSI General Licence INT/2025/8202932 - GOV.UK)
• OFSI amends General Licence for Russian Oil Exempt Projects: On December 17, 2025, OFSI amended General Licence INT/2025/5635700, which authorises the continuation of business operations with the Relevant Subsidiary to the extent they are in relation to the Exempt Projects, subject to certain terms and conditions. This amendment added the Zohr project to the list of Exempt Projects. Additionally, the permissions of the General Licence were amended. The date of expiration of the General Licence depends on the Exempt Project, with the expiry date being 14 October 2027 for most Exempt Projects. (GL_Document_Dec_2025_INT.2025.5635700.pdf; PN_Document_Dec_2025_for_INT.2025.5635700.pdf)

Myanmar sanctions

• OFSI issues General Licence for humanitarian activity in Myanmar: On December 19, 2025, OFSI issued General Licence INT/2025/8257372 which authorises persons to provide humanitarian assistance, other activities that support basic human needs and facilitate the timely provision of those activities in Myanmar. This General Licence expires on 31 January 2026. (INT.2025.8257372_Myanmar_Humanitarian_Activity_GL__.pdf; OFSI General Licence INT/2025/8257372 - GOV.UK)

Syria sanctions

• UK Government adds 3 entities and 6 individuals to the UK sanctions list under the Syrian regime: On December 19, 2025, OFSI added three entities and six individuals to the UK sanctions list under the Syrian regime. These individuals and entities are subject to an asset freeze. (Notice_Syria_191225.pdf)
• UK Government removes four entries from the UK sanctions list under the Syrian regime: On December 17, 2025, OFSI removed Mohammad Ali Jafari, Hossein Taeb, the Islamic Revolutionary Guard Corps (IRGC) QODS Force and the Scientific Studies and Research Centre (SSRC) from the UK sanctions list under the Syrian regime. Mohammad Ali Jafari and Hossein Taeb remain subject to an asset freeze under the Iran regime, the Islamic Revolutionary Guard Corps (IRGC) QODS Force remains subject to an asset freeze under the Iran (Nuclear) regime and the Scientific Studies and Research Centre (SSRC) remains subject to an asset freeze under the Chemical Weapons regime. (Notice_Syria_171225.pdf; Syria financial sanctions: list of asset-freeze targets - GOV.UK)

Iran sanctions

• OFSI amends General Licence for payments relating to remuneration, allowances and contractual or statutory redundancy payments for UK employees and directors: On December 19, 2025, OFSI amended General Licence INT/2025/7628424, which allows for DPs or Persons acting on behalf of DPs to make payments for remuneration, allowances and contractual or statutory redundancy payments to UK Employees and UK Directors, pensions of UK employees, fees and others costs relating to provision of IT services and fees or other costs related to the provision of UK chartered or certified accountancy services., under the Iran Nuclear Regulations. The amendments were to include changes introduced on 28 October 2025, which were inadvertently omitted from the earlier amendments made to the General Licence on 17 December 2025. This General Licence expires on 22 April 2026. (INT-2025-7628424.pdf; Publication_Notice_Document_-_INT-2025-7628424.pdf)
• OFSI amends General Licence for payments relating to remuneration, allowances and contractual or statutory redundancy payments for UK employees and directors. On December 17, 2025, OFSI amended General Licence INT/2025/7628424, which allows for DPs or Persons acting on behalf of DPs to make payments for remuneration, allowances and contractual or statutory redundancy payments to UK Employees and UK Directors, pensions of UK employees, fees and others costs relating to provision of IT services and fees or other costs related to the provision of UK chartered or certified accountancy services., under the Iran Nuclear Regulations. The amendments were a change to the definition of "IT Providers" and to Permission 4.I. This General Licence expires on 22 April 2026. (INT-2025-7628424.pdf; Publication_Notice_Document_-_INT-2025-7628424.pdf)
• UK Government amends two entries from the UK sanctions list under the Iran regime: On December 17, 2025, OFSI amended the entries for Mohammad Ali Jafari and Hossein Taeb, on the UK sanctions list under the Iran regime. Mohammad Ali Jafari and Hossein Taeb remain subject to an asset freeze. (Notice_Iran_171225.pdf; Iran financial sanctions: list of asset-freeze targets - GOV.UK)
• UK Government removes one entry and amends one entry from the UK sanctions list under the Iran (Nuclear) regime: On December 17, 2025, OFSI removed Mohammad Ali Jafari and amended the entry for the Islamic Revolutionary Guard Corps (IRGC) QODS Force on the UK sanctions list under the Iran (Nuclear) regime. Mohammad Ali Jafari and the Islamic Revolutionary Guard Corps (IRGC) QODS Force remain subject to an asset freeze. (Notice_Iran__Nuclear__171225.pdf; Iran (nuclear) financial sanctions: list of asset-freeze targets - GOV.UK)

Chemical weapons sanctions

• UK Government amends one entry from the UK sanctions list under the Chemical Weapons regime: On December 17, 2025, OFSI amended the entry for the Scientific Studies and Research Centre (SSRC) on the UK sanctions list under the Chemical Weapons regime. The Scientific Studies and Research Centre (SSRC) remains subject to an asset freeze. (Notice_Chemical_Weapons_171225.pdf; Chemical weapons financial sanctions: list of asset-freeze targets - GOV.UK)

UK sanctions

• OFSI amends General Licence for Legal Services and publishes related FAQ: On December 17, 2025, OFSI amended General Licence INT/2025/7323088, to correct a previous administrative error and clarify that the definition of "Legal Services" includes legal advice and/or representation in dispute resolution and not merely in court. This General Licence expires 28 April 2026. OFSI also published FAQ 175, which similarly clarifies that legal services received during a dispute resolution are covered by this General Licence. (20251211_INT.2025.7323088_GL.pdf; 20251211_INT.2025.7323088_PN__1_.pdf; UK Financial Sanctions FAQs - GOV.UK)

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This Mayer Brown article provides information and comments on legal issues and developments of interest. The foregoing is not a comprehensive treatment of the subject matter covered and is not intended to provide legal advice. Readers should seek specific legal advice before taking any action with respect to the matters discussed herein.

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