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 issues sectoral software sanctions guidance under Russia regime: On April 24, 2025, the UK Government published guidance on the sectoral software sanctions under the Russia Regime following revisions to the Russia sanctions regulations pursuant to the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2025. Among other things, the guidance provides information on compliance with these sanctions and a description of what information to include in licence applications related to the corresponding prohibitions. (https://www.gov.uk/government/publications/complying-with-sectoral-software-sanctions/complying-with-sectoral-software-sanctions)
- OFSI extends General Licence relating to insolvency payments for GTLK: On April 24, OFSI amended general licence INT/2023/3263556, which authorises payments and certain activities relating to the insolvency proceedings of certain GTLK companies. The amendment extends the General Licence by five years to 31 July 2030. (INT-2023-3263556_GL.pdf)
- UK updates General Trade Licence and related guidance on Russian synthetic diamonds processed in third countries: On April 24, 2025, the UK government updated its general trade licence for sanctioned Russian diamonds processed in third countries to align the definition of 'relevant processed diamond' with the updated Russia Regulations, namely to clarify that the prohibitions apply to diamonds mined in Russia. The UK government updates its associated guidance and updated a notice to importers in relation to these changes. (https://www.gov.uk/government/publications/general-trade-licence-for-sanctioned-russian-diamonds-processed-in-third-countries#full-publication-update-history; Guidance on third country processed Russian synthetic diamonds measures - GOV.UK; https://www.gov.uk/government/publications/notice-to-importers-2953-russia-import-sanctions#full-publication-update-history)
- UK issues new Russia sanctions FAQs to reflect Russian bank mergers: On April 23, 2025, OFSI published 3 new Russia sanctions FAQs following the merger of Rosbank PJSC with TBank and Bank Otkritie with BM-Bank. The FAQs indicate that any person holding an OFSI licence relating to a bank that no longer exists as a separate entity should immediately request an amendment to the licence from OFSI. OFSI has already amended any live general licences affected by these mergers. (UK Financial Sanctions FAQs - GOV.UK)
Syria Sanctions
- UK government updates 348 entries on the UK Sanctions List under the Syria regime: On April 25, 2025, the UK government amended 348 entries on the UK sanctions list to reflect amendments to the Syria (Sanctions) (EU Exit) Regulations 2019. The statement of reasons for these entries has been amended to reflect the changed political situation in Syria and the amended regulations designations. (Notice_Syria_250425.pdf; https://www.gov.uk/government/news/uk-bolsters-support-for-syrian-people-by-amending-syria-sanctions)
- UK revokes sanctions against 12 Syrian entities, including defence and intelligence agencies: On April 24, 2025, the UK government lifted asset freezes on 12 Syrian entities, including the Syrian Ministry of Defence, Ministry of Interior and certain media companies. According to the UK Government, these measures will support Syria's transition to a more stable and prosperous country. (https://assets.publishing.service.gov.uk/media/6809ea4d2a86d6dfb2b527a2/Notice_Syria_240425.pdf; https://www.gov.uk/government/news/uk-bolsters-support-for-syrian-people-by-amending-syria-sanctions)
Other Sanctions
- UK revises open general export licence for oil and gas exploration: On April 23, 2025, the ECJU published Notice to Exporters 2025/10 noting a revision to 'Open general export licence oil and gas exploration: dual use items' to reinclude the UK Continental Shelf as a permitted destination. (Open General Export Licence (Oil and Gas Exploration: Dual-Use Items)
- UK issues technology transfer sanctions guidance under Russia regime: On April 24, 2025, the UK Government published guidance on the technology transfer sanctions under the Russia Regime following revisions to the Russia sanctions regulations pursuant to the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2025. Among other things, the guidance provides information on compliance with these sanctions and a description of what information to include in licence applications related to the corresponding prohibitions. (https://www.gov.uk/government/publications/complying-with-technology-transfer-sanctions/complying-with-technology-transfer-sanctions)
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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.
