Sanctions Tracker: UK Round-up, Including New Sanctions Legislation

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The UK has introduced sweeping changes to its sanctions framework through new Russia-related designations and comprehensive legislative amendments affecting multiple regimes. These developments include expanded end-use controls, revised licensing grounds, and updated reporting thresholds that fundamentally alter compliance obligations for businesses operating in sanctioned sectors.

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New Russia-related designations

The UK has announced new designations under both the Russia and Global Irregular Migration regimes, targeting individuals trafficking vulnerable migrants to fight in the war and companies supplying Russia’s drone factories. The full list of 35 individuals and entities that are now subject to asset freeze sanctions can be found here.

Further Russia-related designations also target 85 individuals and entities said to be involved in the forced deportation of Ukrainian children and Russian information warfare campaigns (see press release). The full list is available here.

New sanctions legislation

The Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026 (the “Regulations”) have recently come into force and make a number of changes across UK sanctions regimes.

In particular:

The monetary thresholds used in the definitions of “high value dealer” and “art market participant” (both sectors which are subject to mandatory sanctions breach reporting obligations) have been amended so as to express relevant thresholds in GBP rather than EUR. This aligns with upcoming changes to the UK anti-money laundering regime.
The Regulations confirm that OFSI and other authorities can send notices for licences electronically, without requiring consent for this approach.
The Regulations amend the existing exception in a number of UK sanctions regimes relating to Treasury debt (the exception is discussed in our previous post). The wording of the exception has been broadened to permit activity to satisfy an obligation owed by any person (previously by HM Treasury) in respect of Treasury debt.
The Regulations broaden the “prior obligations” licensing ground. As previously drafted, this referred to the satisfaction of a designated person’s obligation “by the use of [their] frozen funds or economic resources”. The revised licensing ground simply refers to the satisfaction of an obligation of a designated person (i.e. by any means). The Explanatory Memorandum notes that this will allow for more effective licensing, while preserving OFSI’s ability to scrutinise all applications to prevent circumvention.
The Regulations introduce new sanctions end-use controls under which the export of sanctioned goods to a non-sanctioned jurisdiction is prohibited without a licence once the exporter has been informed of the risk of a specific export to a third country being diverted to a sanctioned jurisdiction or sanctioned person. Exporters may be informed of this risk by the Department for Business and Trade via direct contact (through the Office of Trade Sanctions Implementation (“OTSI”)) or through HMRC’s national clearance hub. OTSI has published guidance on these new measures which includes certain case studies on the process.

The amendments came into force on 13 May 2026.

New EU Russia sanctions package

The EU has recently adopted its 20^th package of Russia sanctions, encompassing 120 new designations and other restrictive measures addressing Russia’s energy revenues, financial sector, trade links and circumvention.

Full details can be found in this post.

OTSI trade licensing guidance

Following its assumption of trade licensing powers (see our previous post for further detail), OTSI has published guidance on how it assesses applications for trade sanctions licences. Various other OTSI and other guidance documents have also been updated to reflect OTSI’s new licensing remit.

OFSI: new general licence (“GL”) and updated FAQs

The Office of Financial Sanctions Implementation (“OFSI”) has issued a new legal services General Licence, following the expiry of the previous GL. The new GL expires on 28 October 2026.

OFSI has also amended its FAQs on financial sanctions to reflect the issuance of the new GL as follows:

FAQs 50 and 57 (which relate to the legal services GL) have been amended;
FAQ 170 (relating to the previous iteration of the GL has been withdrawn; and
a new FAQ 184 has been added, setting out the changes to the legal services GL.

Ten years of OFSI

As mentioned in our previous update, OFSI is currently commemorating its tenth anniversary. In this regard, it has published a blog post with reflections on its recently held international conference.

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.

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