UK Weekly Sanctions Update - Week of August 4, 2025

RUSSIA SANCTIONS

• UK Government extends Mongolian Energy Payments General Licence: On August 7, 2025, OFSI extended General Licence INT/2022/2085212, which authorises payments to four Russian banks or their subsidiaries for the purpose of making energy available for use in Mongolia, subject to certain terms and conditions. The General Licence has been extended to August 14, 2027. (07.08.2025_INT.2022.2085212_Mongolia_energy_General_Licence.pdf).
• UK Government updates Countering Russian Sanctions Evasion guidance to businesses on higher risk goods: On August 4, 2025, the UK government updated its guidance for UK exporters on countering Russian sanctions evasion and circumvention. Among other things, the guidance identifies goods on the common high priority list and goods at higher risk of circumvention, and states that businesses should consider conducting enhanced due diligence on customers based within inter alia Armenia, China, India, Kazakhstan, Kyrgyzstan, Malaysia, Serbia, Thailand, Türkiye, UAE, Uzbekistan and Vietnam. (Countering Russian sanctions evasion - guidance for businesses - GOV.UK).

OTHER SANCTIONS

• UK High Court provides clarity on the meaning of “reasonable cause to suspect” in Tonzip Maritime Ltd v 2Rivers PTE Ltd: On July 31, 2025, the UK High Court found in Tonzip Maritime Ltd v 2Rivers PTE Ltd that a shipowner’s decision to refuse their charterers' orders to load a cargo, on the basis that doing so would expose them to sanctions, was not a decision that a reasonable shipowner could reasonably have come to. In particular, the court determined that the shipowner’s reliance on a Refinitiv report indicating the shipper’s indirect and previous association with a sanctioned individual was not a reasonable basis for terminating the contract. (Tonzip Maritime Ltd v 2Rivers PTE Ltd [2025] EWHC 2036 (Comm) (31 July 2025)).

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