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 amends General Licence relating to payment of bank service fees: On September 26, 2025, OFSI amended General Licence INT/2022/2104808, which authorises a bank to receive service fees from accounts held by designated persons arising from the routine holding or maintenance of those accounts. Among other things, the updated general licence clarifies that payments by designated persons under the licence are not restricted to those made from frozen funds. OFSI also added FAQ 167 in relation to the application of this General Licence. (Bank_Charges_GL.pdf; https://www.gov.uk/government/publications/uk-financial-sanctions-faqs/uk-financial-sanctions-faqs).
- UK Government publishes new guidance summarising exceptions to Russia trade and transport sanctions and amendments to the Russia sanctions regulations: On September 25, 2025, the UK Government published new guidance that summarises (i) exceptions to Russia trade and transport sanctions, which provides a list of exceptions that allow activities otherwise subject to sanctions in certain defined circumstances; and (ii) amendments to the Russia sanctions regulations, which provides a non-exhaustive list of statutory instruments that have made changes to the UK's Russia sanctions regulations. (Look up exceptions to the Russia trade and transport sanctions - GOV.UK; Look up amendments to the Russia sanctions regulations - GOV.UK).
- UK Government amends one entry on the UK sanctions list under the Russia regime: On September 23, 2025, the UK amended the entry for Yuri Olegovish Denisov on the UK sanctions list under the Russia regime. This individual remains subject to an asset freeze. (https://assets.publishing.service.gov.uk/media/68d27d00ca266424b221b185/Notice_Russia_230925.pdf).
- UK Government removes one entry on the UK sanctions list under the Russia regime: On September 22, 2025, the UK removed the entry for Tatiana Evtushenkova from the UK sanctions list under the Russia regime. (https://assets.publishing.service.gov.uk/media/68d12ace275fc9339a248af1/Notice_Russia_220925.pdf)
Counter Terrorism sanctions
- UK Government adds two entries to the UK sanctions list under the Counter Terrorism Regime: On September 25, 2025,OFSI added Rampage Productions and Embers of an Empire to the UK sanctions list under the Counter Terrorism Regime. (Notice_Counter_Terrorism__Domestic__250925.pdf).
Other Sanctions
- OFSI amends General Licence relating to payments to energy companies for gas and electricity: On September 26, 2025, OFSI amended General Licence INT/2022/2300292, which authorises certain payments to energy companies for gas and electricity, by or on behalf of designated persons, subject to certain terms and conditions. Among other things, the updated general licence clarifies that payments by designated persons under the licence are not restricted to those made from frozen funds and amends the reporting requirements thereunder. OFSI also added FAQ 165 in relation to the application of this General Licence. (GL_Gas_and_Electricity.pdf; https://www.gov.uk/government/publications/uk-financial-sanctions-faqs/uk-financial-sanctions-faqs).
- OFSI amends General Licence relating to payments to water companies for water and sewage: On September 26, 2025, OFSI amended General Licence INT/2023/3179120, which authorises certain payments to water companies for water and/or sewerage services to a UK property owned or rented by a designated person, subject to certain terms and conditions. Among other things, the updated general licence clarifies that payments by designated persons under the licence are not restricted to those made from frozen funds and amends the reporting requirements thereunder. OFSI also added FAQ 165 in relation to the application of this General Licence. (https://assets.publishing.service.gov.uk/media/68d653079ce370a7e0a0fd23/GL_Water_and_Sewage.pdf; https://www.gov.uk/government/publications/uk-financial-sanctions-faqs/uk-financial-sanctions-faqs).
- OFSI issues General Licence relating to payments made by HMRC: On September 26, 2025, OFSI issued General Licence INT/2025/7328184, which authorises HMRC to make certain payment to a frozen UK bank account of a designated person or to set off certain payments against any liability owed by a designated person to HMRC. (Revenue_Authorities_Payments_GL_INT.2025.pdf).
- UK Government publishes starter guide to UK sanctions: On September 22, 2025, the UK Government published a starter guide to UK sanctions, which provides information for businesses and organisations that need to understand more about what sanctions area and how they work. (Starter guide to UK sanctions - GOV.UK).
- UK Government clarifies HM Treasury Debt Exception in update to UK financial sanctions general guidance: On September 22, 2025, OFSI amended section 6.21 (HM Treasury debt exception) of its UK financial sanctions general guidance to clarify that the reference in the exception to an obligation owed by HM Treasury to a UN designated person should also include an obligation owed by any other person to the UN designated person in respect of HM Treasury debt. (UK financial sanctions general guidance - GOV.UK).
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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.
