Sanctions tracker – round-up of recent UK sanctions developments

New UK sanctions guidance for non-UK businesses

The UK's Foreign, Commonwealth and Development Office (the "FCDO") has published new sanctions guidance for non-UK businesses. This comprises general guidance (the "Guidance") as well as specific guidance for businesses operating in Armenia, Georgia, Kazakhstan, Kyrgyzstan and Uzbekistan (together, the "Country-Specific Guidance").

The Guidance aims to help businesses in third countries to seek to avoid the circumvention of UK sanctions, and is specific to sanctions targeting Russia. It includes the following key elements:

• information on the jurisdictional scope of UK sanctions;
• the risks for businesses that facilitate the circumvention of UK sanctions (emphasising the UK's willingness to designate third country businesses engaged in activity which undermines the objectives of the UK's Russia sanctions);
• an overview of the UK's sanctions on Russia; and
• practical steps to manage sanctions risk and promote compliance (including a list of sanctions compliance red flags).

The Country-Specific Guidance contains similar information, along with guidance on relevant local law measures in each jurisdiction.

New UK sanctions legislation

The UK government has recently published the Sanctions (EU Exit) (Treasury Debt) Regulations 2025 (the "2025 Regulations") which amend various existing sanctions regimes to introduce a new exemption from the asset freeze in relation to Treasury debt. The exemption provides that the asset freeze / making available prohibitions in the relevant regime are not contravened by any act done by a person to transfer funds to a UN designated person (or any other person where the effect of the transfer is to make funds available to or for the benefit of such a designated person) to satisfy an obligation owed by HM Treasury in respect of Treasury debt. This is subject to the conditions that the transferor: (i) knows or has reasonable cause to suspect that the relevant obligation arose before the date on which the designated person was designated, and (ii) takes reasonable steps to satisfy itself that the funds to be transferred are credited to a "specified account" (a frozen account or other account defined in the 2025 Regulations).

The Office of Financial Sanctions Implementation ("OFSI") has already issued a General Licence in respect of payments by the UK government / under government debt in relation to UK autonomous sanctions regimes (see our previous post for further detail). The 2025 Regulations apply the same policy to UN sanctions regimes / designated persons, with the General Licence remaining in place for non-UN designated persons.  

The 2025 Regulations will come into force on 10 July 2025.

New UK designations

On 17 June, the UK announced a further round of Russia sanctions designations targeting the financial, military and energy sectors. The new sanctions targets include (among others): (i) 20 oil tankers said to be part of the "shadow fleet"; (ii) two UK residents said to be responsible for supplying Russia with high-tech electronics, (iii) two entities involved in crewing and managing shadow fleet vessels, and (iv) the Russian military agency "GUGI".

A full list of the designations is available here. 

Conviction under Terrorism Act 2000

The Metropolitan Police has announced that an art dealer has pleaded guilty to eight counts of failing to make a disclosure during the course of business within the regulated sector, contrary to section 21A of the Terrorism Act 2000 (the "TA"). The charges relate to the sale of art to an individual subject to UK sanctions who is suspected of financing Hezbollah.

This is the first conviction of a specific offence under section 21A of the TA and the investigation was carried out in partnership with OFSI, HM Revenue & Customs, and the Met's Arts and Antiques Unit.

OFSI publishes new threat assessment report and other guidance

OFSI has continued with its range of sectoral threat assessments, publishing a report in relation to the sanctions threat associated with art market participants and high value dealers. Both art market participants and high value dealers became "relevant firms" for sanctions reporting purposes in May 2025 (see our previous post for more detail) and so this assessment is intended to help firms in these sectors comply with their reporting obligations, and with UK financial sanctions, more broadly.

OFSI has continued to update its financial sanctions FAQs. The most recent developments comprise:

• the addition of a new FAQ (152) on the reporting of securities held at designated local Russian registrars;
• the withdrawal of two FAQs (123 and 124) also relating to securities held at local registrars;
• two FAQs on licensing in Crown Dependencies and Overseas Territories (150 and 151); and
• an FAQ on what constitutes an economic resource (149). Of particular note in this response is OFSI's expansive view of this term, which includes the provision of services, as well as physical or intangible assets. The examples given in the FAQ are consultancy, software, property maintenance and publicity.

OFSI has also published a new video series – "Financial Sanctions: The Basics" – to provide high level guidance on OFSI's processes and compliance with financial sanctions obligations.

Sanctions evasion Red Alert

The National Crime Agency (jointly with OFSI and the FCDO) has issued a Red Alert to provide information to assist financial institutions in identifying potential sanctions evasion in relation to the sale of Russian oil and gas.

The Red Alert provides detail of a sanctions evasion and avoidance network used to trade Russian oil and lists red flag indicators which may suggest suspicious activity.

Any firms submitting suspicious activity reports ("SARs") in relation to activity mentioned in the Red Alert should include the codes XXJMLXX and 0774-NECC in their SARs.

FATF issues report on sanctions evasion

The Financial Action Task Force ("FATF") has published a report on complex proliferation financing and sanctions evasion schemes. The report provides a detailed analysis of the evolving methods and techniques used to evade proliferation-financing related sanctions in particular and identifies four major typologies in sanctions evasion: (i) use of intermediaries to evade sanctions, (ii) obscuring beneficial ownership information to access the financial system, (iii) using virtual assets and other technologies, and (iv) exploiting the maritime and shipping sectors.

In the report, FATF outlines common enforcement obstacles and shares examples of good practice in this area. It also provides a list of practical risk indicators to help detect evasion.