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 arbitration costs: On March 28, 2025, the Office of Financial Sanctions Implementation ("OFSI") issued general licence INT/2025/5787748, which authorises certain payments to be made to an Arbitrator or an Arbitration Association in relation to arbitration proceedings, subject to certain terms and conditions, under both the Russia and Belarus regimes. The General Licence takes effect from March 28, 2025, for an indefinite term. (Arbitration_Costs_GL_INT-2025-5787748.pdf; LCIA_Costs_GL_-_INT-2022-1552576_-_PN_-_28_March_2025.pdf)
- OFSI amends General Licence relating to bond amendments
and restructurings: On March 28, 2025, OFSI amended
general licence INT/2023/2824812, which authorises issuers which
may have designated bondholders to effect the terms of a
restricting or amendments agreed between itself and its bondholders
provided no funds or economic resources are made available to a
designated person, subject to certain terms and conditions. The
General Licence was extended by one year to March 27, 2026.
(Non-DP_Bond_Restructuring_GL_INT.2023.2824812.pdf; https://assets.publishing.service.gov.uk/media/67e6827c37baea91c58c9fd2/Non-DP_Bond_Restructuring_GL_INT.2023.2824812_PN.pdf) - OFSI amends General Licence for payments relating to the provision of professional legal services: On March 28, 2025, OFSI amended general licence INT/2024/5334756, which authorises certain payments relating to the provision of professional legal fees, subject to certain terms and conditions, under both the Russia and Belarus regimes. The amendments expand the definition of designated person under the general licence to include corporates and clarify that "legal services" includes representation in dispute resolution matters. The General Licence expires on 28 April 2025. (Legal_Services_GL_-_INT-2024-5334756_-_Amendment_28.03.25.pdf)
- UK Government amends two entries on UK sanctions list under the Russia regime: On March 27, 2025,the UK Government amended the entries for two entities(2Rivers DMCC and 2Rivers PTE LTD) on the UK sanctions list under the Russia regime. (Notice_Russia_270325.pdf)
- OFSI amends General Licence for payments involving Russian Railways and Lithuanian Railways: On March 27, 2025, OFSI amended general licence INT/2023/2883496, which inter alia authorises certain payments involving Russian Railways and Lithuanian Railways relating to the transit of persons between the Kaliningrad Region and other parts of Russia via the passenger rail service operated by Lithuanian Railways, subject to certain terms and conditions. The expiry date of the General Licence was extended by two years to April 13, 2027. (INT_2023_2883496_Lithuania_Rail_General_Licence.pdf)
- UK Government amends one entry on UK sanctions list under the Russia regime: On March 24, 2025,the UK Government amended the entry forTigran Oganesovich Khudaverdyan on the UK sanctions list under the Russia regime. (Notice_Russia_240325.pdf)
- OFSI amends General Licence for humanitarian activity: On March 24, 2025, OFSI amended General Licence INT/2022/1947936, which authorises the performance of certain activities relating to the delivery of humanitarian assistance and the support of basic human needs in relation to the conflict in Ukraine and non-government controlled Ukrainian territory, subject to certain terms and conditions. In particular, Rosbank PJSC and Tinkoff Bank were removed from, and TBank was added to, Annex I of the general licence. (General_Licence_INT-2022-1947936.pdf).
- OFSI amends General Licence for Mongolia energy payments: On March 24, 2025, OFSI amended General Licence INT/2022/2085212, which authorises certain payments to be made to certain sanctioned banks for the purpose of making energy available for use in Mongolia, subject to certain terms and conditions. In particular, Rosbank PJSC, which has merged with T-Bank, has been removed and replaced by TBank under the definition of "Sanctioned Bank" under the licence. The General Licence expires on 14 August 2025. (27.07.2023_Mongolia_energy_General_Licence.pdf).
Belarus Sanctions
- OFSI issues General Licence for arbitration costs: On March 28, 2025, the Office of Financial Sanctions Implementation ("OFSI") issued general licence INT/2025/5787748, which authorises certain payments to be made to an Arbitrator or an Arbitration Association in relation to arbitration proceedings, subject to certain terms and conditions, under both the Russia and Belarus regimes. The General Licence takes effect from March 28, 2025, for an indefinite term. (Arbitration_Costs_GL_INT-2025-5787748.pdf; LCIA_Costs_GL_-_INT-2022-1552576_-_PN_-_28_March_2025.pdf)
- OFSI amends General Licence for payments relating to the provision of professional legal services: On March 28, 2025, OFSI amended general licence INT/2024/5334756, which authorises certain payments relating to the provision of professional legal fees, subject to certain terms and conditions, under both the Russia and Belarus regimes. The amendments expand the definition of designated person under the general licence to include corporates and clarify that "legal services" includes representation in dispute resolution matters. The General Licence expires on 28 April 2025. (Legal_Services_GL_-_INT-2024-5334756_-_Amendment_28.03.25.pdf)
Iran Sanctions
- Standard Chartered fails to narrow £1.5bn lawsuit relating to Iran: On March 25, 2025, Standard Chartered lost a bit to halve the value of a c. £1.5bn London lawsuit brought by investors in connection with allegations that the bank violated U.S. sanctions against Iran in a more widespread way that it had previously admitted. The bank previously paid $1.1 billion to US and UK authorities in 2019 in connection with transactions that violated sanctions against Iran and other countries. The case now proceeds to trial in October 2026. (https://www.judiciary.uk/wp-content/uploads/2025/03/Various-Claimants-v-Standard-Chartered-25.03.25.pdf; https://www.reuters.com/sustainability/boards-policy-regulation/stanchart-loses-bid-cut-shareholders-19-billion-uk-lawsuit-half-2025-03-25/).
Global Human Rights Sanctions
- UK Government amends one entry on UK Sanctions list under the Global Human Rights Sanctions Regime: On March 27, 2025, the UK Government amended one entry for Wasantha Karannagoda under the Global Human Rights Sanctions Regime. (Notice_Global_Human_Rights_270325.pdf)
- UK Government adds four entries on UK sanctions list under the Global Human Rights Sanctions Regime: On March 24, 2025,the UK Government added four individuals (Shavendra Silva, Wasantha Karannagoda, Jagath Jayasuriya, and Vinayagamoorthy Muralitharan) to the UK sanctions list under the Global Human Rights Sanctions Regime. (Notice_Global_Human_Right_240325.pdf)
Other sanctions
- OFSI amends General Licence relating to presidential supervision and protection of the integrity of the UK financial system: On March 27, 2025, OFSI amended General Licence INT/20221280976, which authorises a UK regulatory authority involved in the regulation of financial services to engage in certain activities in respect of a UK sanctions target, including activities that relate to prudential supervision or protecting, maintaining or enhancing the stability of the UK financial system. The General Licence has been extended indefinitely and to apply to all persons designated under the UK's autonomous sanctions regimes listed in Annex 1 of the General Licence. (INT20221280976_Amendment_27.03.2025.pdf)
- UK Government responds to question on effectiveness of Russia sanctions implemented in the Cayman Islands: On March 26, 2025, Stephen Doughty MP, the Minister of State for Europe, North America and Overseas Territories, responded to a written question relating to the implementation of sanctions against Russia by the Cayman Islands. Among other things, the Minister stated that the effective implementation of sanctions against Russia is a UK Government priority, and that the UK recently convened sanctions experts from across the Overseas Territories to share best practice and strengthen collective efforts. (https://questions-statements.parliament.uk/written-questions/detail/2025-03-18/38999)
- OFSI adds new FAQ relating to the creation of suspense accounts to hold frozen funds: On March 27, 2025, the Office of Financial Sanctions Implementation ("OFSI") added FAQ Q.145 which states that "OFSI does not consider it to be in the public interest to take enforcement action in relation to the creation and use of suspense accounts for the express purpose of [holding frozen funds]" and that any relevant institution that uses a suspense account in this way can notify OFSI in its frozen assets reporting.
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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.
