UK Weekly Sanctions Update - Week Of March 31, 2025

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 publishes blog post on lessons for industry from recent enforcement action: On April 4, 2025, the Office of Financial Sanctions Implementation ("OFSI") outlined key lessons for industry following the imposition of a £465,000 monetary penalty against Herbert Smith Freehills CIS LLP. In particular, the blog post encourages market participants to (i) understand their exposure to sanctions risks; (ii) adhere properly to any sanctions policies and processes they have in place, and (iii) fully consider ownership and control in any sanctions assessment. (HSF Moscow Penalty: Key Lessons for Industry – Office of Financial Sanctions Implementation)

Global Anti-Corruption Sanctions

• UK Government adds 13 entries on UK sanctions list under the Global Anti-Corruption Sanctions Regime: On April 2, 2025,the UK Government added 13 entries to the UK sanctions list under the Global Anti-Corruption Sanctions Regime. According to the UK Government, these measures target cronies used by corrupt leaders to undermine democracy and the rule of law in Guatemala, Moldova and Georgia. (Notice_Global_Anti_Corruption_020425.pdf)

Other Sanctions

• OFSI publishes Legal Services Threat Assessment: On April 3, 2025, OFSI published a report outlining its assessment of threats to sanctions compliance involving UK legal services providers since February 2022. The report notes that, since February 2022, the legal services sector has submitted the second highest number of suspected breach reports to OFSI by sector. Among the key judgements set out in the report, OFSI states that: (i) it is likely that UK trust and company services providers likely have not self-disclosed all suspected breaches to OFSI; (ii) it is almost certain that most non-compliance by UK legal services providers is due to breaches of OFSI licence conditions; (iii) it is almost certain that complex corporate structures linked to Russian DPs have obfuscated asset ownership and control; and (iv) it is likely that Russian DPs have transferred assets to non-designated individuals. (https://assets.publishing.service.gov.uk/media/67ee635698b3bac1ec299c3e/OFSI_Legal_Services_
  Threat_Assessment.pdf)
• UK Government to Introduce Urgent Designation Procedure across Certain Sanctions Regimes: On March 27, 2025, the UK Government laid before Parliament the Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2025, which incorporate into 26 UK sanctions regimes the "urgent procedure" for sanctions designations. This procedure was initially incorporated into the Sanctions and Anti-Money Laundering Act to in March 2022 via the Economic Crime (Transparency and Enforcement) Act 2022. These amendments will come into force on April 18, 2025. (The Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2025)