On 22 July 2025, the UK’s Office of Financial Sanctions Implementation (OFSI) launched a major consultation proposing wide-ranging enhancements to its civil enforcement framework (the Consultation). The Consultation is open...more
On 14 July 2025, the United Kingdom’s Foreign, Commonwealth and Development Office released important sanctions guidance aimed specifically at non-UK companies operating outside the United Kingdom, with a special focus on...more
On 18 June 2025, the UK Office for Financial Sanctions Implementation (OFSI) released a Threat Assessment (the Assessment) targeting Art Market Participants (AMPs) and High-Value Dealers (HVDs). This follows new rules from 14...more
7/23/2025
/ AML/CFT ,
Anti-Money Laundering ,
Art ,
Due Diligence ,
Economic Sanctions ,
Financial Crimes ,
Fine Art ,
Office of Financial Sanctions Implementation (OFSI) ,
Reporting Requirements ,
Risk Management ,
UK
The United Kingdom’s Foreign, Commonwealth and Development Office has published guidance on United Kingdom’s Russia sanctions compliance for non-UK businesses operating outside the United Kingdom (the Guidance). It also...more
On 18 June 2025, the UK Office for Financial Sanctions Implementation (OFSI) published a threat assessment (the Assessment) on compliance with UK sanctions and money laundering law for art market participants (AMPs) and high...more
7/15/2025
/ AML/CFT ,
Anti-Money Laundering ,
Art ,
Beneficial Owner ,
Digital Assets ,
Due Diligence ,
Economic Sanctions ,
Money Laundering ,
Office of Financial Sanctions Implementation (OFSI) ,
Penalties ,
Reporting Requirements ,
Risk Assessment
On 15 May 2025, the UK government published a policy paper summarising findings from a cross-government review of sanctions implementation and enforcement. The Foreign, Commonwealth and Development Office led the review in...more
On 8 May 2025, the United Kingdom’s Office of Financial Sanctions Implementation (OFSI) of HM Treasury published a penalty notice regarding a breach of financial sanctions by a UK registered company—Svarog Shipping & Trading...more
5/30/2025
/ Compliance ,
Economic Sanctions ,
Enforcement Actions ,
Financial Crimes ,
Financial Institutions ,
Government Agencies ,
Office of Financial Sanctions Implementation (OFSI) ,
Penalties ,
Reporting Requirements ,
Request For Information ,
UK
In a bid to further increase the pressure on Russia, the Council of the European Union has adopted additional measures which have been introduced in its 16th sanctions package. The new measures amending the framework Council...more
The United Kingdom’s Office of Financial Sanctions Implementation (OFSI) has published a report detailing suspected breaches of UK financial sanctions involving UK property and related services firms since February 2022 and...more
4/28/2025
/ Anti-Money Laundering ,
Beneficial Owner ,
Economic Sanctions ,
Landlords ,
Money Laundering ,
Office of Financial Sanctions Implementation (OFSI) ,
Property Owners ,
Real Estate Transactions ,
Reporting Requirements ,
Suspicious Activity Reports (SARs) ,
UK
In its first-ever threat assessment of the UK legal sector, the UK’s Office of Financial Sanctions Implementation (OFSI) has raised red flags with regards to suspected sanctions breaches involving UK legal services providers...more
On 13 February 2025, the Office of Financial Sanctions Implementation (OFSI) published its assessment of suspected sanctions breaches involving financial services firms since February 2022 (the Assessment). The Assessment...more
On 24 September 2024, the G7 released updated guidance on the prevention of evasion of export controls and sanctions imposed on Russia. The aim of the guidance is to “assist industry in identifying Russian evasion practices...more
On 12 September 2024, the UK government released the new Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 (the Regulations), which will come into force on 10 October 2024. The Regulations grant the...more
The Impact of the EU and UK Russian Sanctions Regime on the Luxury Goods Sector - As the EU and UK Russian sanctions regimes continue to evolve, export controls are now affecting industries previously not often subject to...more
The following alert provides an update on recent sanctions developments, including: The publication of the UK government’s first sanctions strategy. The announcement of over 50 new sanctions. Measures to strengthen the Oil...more
4/12/2024
/ Asset Freeze ,
Economic Sanctions ,
EU ,
Export Controls ,
Exports ,
Imports ,
New Regulations ,
Oil & Gas ,
Regulatory Oversight ,
Russia ,
Sanctions and Anti-Money Laundering Act 2018 (SAMLA) ,
Trade Relations ,
UK
In October, the Court of Appeal suggested all companies operating in Russia could be considered to be sanctioned under UK law because they are potentially controlled by President Putin. This caused understandable alarm to...more
A non-binding passage in a recent Court of Appeal judgment has suggested that any company based in or incorporated in Russia could be subject to the same UK sanctions as Vladimir Putin. The UK Foreign, Commonwealth and...more
Introduction - Since the Russian invasion of Ukraine in February 2022 the UK has introduced an unprecedented number and variety of sanctions. The FCA has recently assessed the sanctions controls of over 90 financial service...more
July was another busy month for sanctions in the United Kingdom. We have prepared a briefing on the key recent developments and suggested practical steps for companies and legal professionals to assist in understanding the...more
The United Kingdom export control authorities continue escalating sanctions and export controls in relation to Russia and Belarus. We have summarised below the key points from some of the most recent developments and provided...more
In a set of actions in coordination with G7 allies, US and UK export control authorities recently announced significant escalations of sanctions and export controls against Russia and Belarus. These actions indicate continued...more
A recent judgment by London’s Commercial Court has shed light on the effect of Russian sanctions on ongoing litigation in the United Kingdom (UK). The Sanctions and Anti-Money Laundering Act 2018 (SAMLA) provides the main...more
The following alert provides an update on recent sanctions developments including: 1. A £30,000 fine imposed for breaches of UK sanctions; 2. The expansion of the prohibition on providing professional services to persons...more
On Thursday 10 November 2022, the UK Office of Financial Sanctions Implementation (OFSI), published its 2021-2022 annual review, highlighting its shift towards a more proactive rather than reactive compliance and enforcement...more
On 17 May 2022 the UK Financial Conduct Authority (FCA) made an appeal for people to report to it regarding firms on the Financial Services Register or other FCA registers, or companies with UK listed securities that have...more