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
- OFSI issues General Licence for petrol station payments involving Gazprom Neft and its subsidiaries in Kyrgyzstan and Tajikistan: On March 14 2025, the Office of Financial Sanctions Implementation ("OFSI") granted a general licence which authorises UK nationals to purchase petrol at any petrol station in Kyrgyzstan or Tajikistan that is owned or controlled by Gazprom Neft or one of its subsidiaries, provided that the petrol is for the UK national's personal vehicle, subject to certain terms and conditions. The General Licence expires on March 15, 2027. (INT.2025.5886860.pdf).
- UK Minister states that no oil was exported from the UK to Russia in 2024 or 2024: On March 7, 2025, Douglas Alexander MP, Secretary of State for Business and Trade, stated in a response to a written question that, according to HMRC data, the UK did not export oil to Russia in 2023 or 2024. (https://www.theyworkforyou.com/wrans/?id=2025-02-26.34076.h).
Counter Terrorism (International) Sanctions
- OFSI issues disclosure notice to NGOs for failure to respond to requests for information: On March 14, 2025, OFSI published a disclosure notice in relation to three charities (Sahara Hands, Peculiar Peoples' Palace Ministries, and Impact Planet) for a failure to respond to a request for information ("RFI") from OFSI, notwithstanding numerous efforts by OFSI to contact each charity. OFSI states in its notice that the Disclosure relates to an information offence only, and that OFSI does not hold information that the charities involved have committed any further breach of the regulations. (Disclosure_Notice_Report__14.03.25_Publication_.pdf).
Other sanctions
- Change to the current FCDO sanctions email alert service: On March 14, 2025, the UK Government announced an improved, streamlined UK Government sanctions email alert service. From w/c March 17, the FCDO and OFSI sanctions email alert services will combine with a new service from OTSI to provide joint updates on designations, general licenses, FAQs, and other relevant topics.
- UK Government publishes Anti-Money Laundering and Counter-Terrorist Financing: Supervision Report 2023-24: On March 13, 2025, the UK Government published its annual report on anti-money laundering and counter-terrorist (AML/CTF) supervision for 2023 to 2024. Among other things, the report outlines supervisors' obligations to assess AML/CTF risks, their risk-based approach to monitoring compliance under the MLRs, and their use of enforcement action to promote compliance with AML/CTF standards. (AML_Annual__Report.pdfAML_Annual__Report.pdf).
- OFSI releases additional sanctions guidance for High Value Dealers and Art Market Participants: On March 12, 2025, OFSI released additional sanctions guidance for High Value Dealers (HVD) and Art Market Participants (AMP), covering inter alia common evasion practices, due diligence, reporting, licensing, compliance and penalties, and ownership and control. The guidance has been published to support HVD and AMP in navigating UK financial sanctions and new reporting requirements. OFSI also published new FAQs in response to questions from industry, including letting agents and insolvency practitioners. (High Value Dealers & Art Market Participants guidance - GOV.UK).
- UK Government publishes notice to exporters announcing updates to the UK Strategic Export Control List: On March 11, 2025, the UK Government published a notice to exporters announcing updates to the UK Strategic Export Control List and corresponding updates to UK legislation. The updates include changes to align with amendments under the Wassenaar Arrangement website, changes agreed under the guidelines on the Nuclear Suppliers Group (NSG) website, and changes agreed under the Australia Group. (https://www.gov.uk/government/publications/notice-to-exporters-202506-upcoming-updates-to-the-uk-strategic-export-control-list/nte-202506-upcoming-updates-to-the-uk-strategic-export-control-list).
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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.
