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 Supreme Court hears appeal relating to detained superyacht m.v. Phi: On January 16, 2025, the UK Supreme Court ("UKSC") heard an appeal from Dalston Projects Ltd and others challenging the decision by the UK Secretary of State for Transport ("SST") to detail a luxury yacht, "the Phi" under the Russia regime. The beneficial owner of the yacht, Sergei Naumenko, is not a UK sanctions target. The appeal considers whether the SST's decision to detain the yacht under the UK's Russian sanctions regime should be set aside on (i) human rights, or (ii) public law, grounds. Judgment is awaited. (https://www.supremecourt.uk/cases/uksc-2024-0055)
- UK Supreme Court hears Shvidler de-listing appeal: On January 15, 2025, the UK Supreme Court ("UKSC") heard an appeal from Eugene Shvidler relating to his designation under the Russia regime. Mr Shvidler, a US-British dual national was designated under the Russia regime on 24 March 2022 for being (i) a business partner of Mr Abramovich, and (ii) a former longstanding non-executive director of Evraz, a UK listed company steel manufacturing and mining company. The appeal considers two main issues: (1) did the UK Court of Appeal adopt the wrong approach to determining whether Shvidler's designation was a proportionate interference with his rights under the European Convention on Human Rights (ECHR); and (2) was the Court of Appeal wrong to conclude that maintaining Shvidler's designation was not a breach of his rights under the ECHR? Judgment is awaited. (Shvidler (Appellant) v Secretary of State for Foreign, Commonwealth and Development Affairs (Respondent) - UK Supreme Court)
- UK Government amends one entry on the UK sanctions list under the Russia regime: On January 15, 2025, OFSI amended the entry for Gazprom Neft on the UK sanctions list under the Russia regime. The entry for Gazprom Neft was also updated on January 14, 2025. (Notice_Russia_150125.pdf; Notice_Russia_150125_InvBan.pdf; Notice_Russia_140125.pdf)
Venezuela Sanctions
- UK Government amends one entry on the UK sanctions list under the Venezuela regime: On January 17, 2025, OFSI amended the entry for Domingo Antonio Hernandez Larez on the UK sanctions list under the Venezuela regime. (Notice_Venezuela_170125.pdf)
Other sanctions
- OFSI issues Interim Basic Necessities General Licence for Designated Persons: On January 14, 2025, OFSI issued General Licence INT/2025/5632740, which authorises persons to make up to £350 worth of funds available to or for the benefit of a UK Designated Person ("UK DP") in each of the two months following the date of the UK DP's designation for certain basic necessities, subject to certain terms and conditions. This General License will expire in respect of each UK DP at 23:59 on either the day a specific basic needs licence in respect of that UK DP takes effect, or the day two months after the date of designation of that UK DP (whichever is earlier). This General Licence applies across UK autonomous sanctions regimes, as indicated in the Annex to the licence. (Basic_Necessities_General_Licence_INT.2025.5632740.pdf; Interim_Basic_Necessities__Publication_Notice_INT.2025.5632740.pdf)
- OFSI and OFAC publish memorandum of understanding: On January 13, 2025, OFSI and OFAC published a memorandum of understanding (which is dated October 9, 2024) describing how these enforcement agencies undertake to facilitate the exchange of information between one another on the implementation and enforcement of sanctions. The publication of this MOU reflects more than two years of enhanced partnership between the two agencies, as highlighted in an OFSI blog in November 2024. (OFAC-OFSI_Information_Sharing_MOU_-_signed.pdf; https://ofsi.blog.gov.uk/2024/11/19/strengthening-global-sanctions-two-years-of-enhanced-partnership/)
- NCA publishes letter to Chair of Treasury Select Committee on its role in investigating breaches of financial sanctions; On January 10, 2025, Graeme Biggar CBE, Director General of the National Crime Agency ("NCA") wrote a letter to Dame Meg Hillier MP, Chair of the Treasury Committee, in response to a request for information from the letter sent on December 11, 2024. The letter describes inter alia the role of the NCA in investigating serious criminal breaches of financial sanctions and the proportion of the NCA's workload that relates to financial sanctions. The letter states that there have been no concluded prosecutions under the Sanctions and Anti-Money Laundering Act, and that the NCA has brought charges in one case (in February 2024) in relation to the potential circumvention of sanctions by the former governor of annexed Sevastopol. (https://committees.parliament.uk/publications/46273/documents/232557/default/)
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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.
