Sanctions Tracker

OFSI imposes monetary penalty and issues disclosure notice

The Office of Financial Sanctions Implementation ("OFSI") has announced two further enforcement actions in respect of financial sanctions breaches:

• A Disclosure Notice was published in respect of Vanquis Bank Limited ("Vanquis") in respect of a breach of the UK's Counter-Terrorism sanctions regime. Vanquis had been given advance notice that a suspected customer of the bank was to be designated but the designated person in question was able to withdraw cash from their bank account and make a purchase after designation, due to a delay in processing of the relevant sanctions screening alert.
• A monetary penalty of £152,750 was imposed on Colorcon Limited ("Colorcon") in respect of a breach of the Russia sanctions regime involving the making of payments to non-designated employees and service providers of Colorcon's Moscow office to accounts held with designated banks. Some payments were made under a "wind-down" general licence ("GL"), but Colorcon continued to make payments after that GL had expired, and did not comply with reporting requirements under the GL.

New UK designations

The UK has continued to expand its Russia-related asset freeze to new targets, as set out below:

• The designation of 30 entities and inpiduals supplying key equipment to Russia, plus the specification of 70 ships in the "shadow fleet" (as set out in more detail in this press release).
• The imposition of asset freeze restrictions on eight inpiduals and three organisations affiliated with the Russian state in response to reports of a "Russification" policy being adopted in non-government controlled areas of Ukraine, as described in more detail here.
• The designation of eight targets associated with the Kyrgyz financial sector, which is said to be a route for Russia to attempt to avoid sanctions.
• Additional designations targeting the Russian oil industry including the designation of Rosneft and Lukoil, along with various other targets in the military supply chain. As part of the same package of sanctions, the UK announced that it would ban imports of oil products refined in third countries from Russian-origin crude oil.

OFSI publishes additional guidance

OFSI has published a number of additional guidance notes in relation to financial sanctions. These include the following:

• The addition of new FAQs regarding certain GLs, including in relation to the ability of a designated person to make permitted payments from non-frozen bank accounts.
• A new look-up feature has been published which provides links to all statutory instruments that have made changes to the UK's Russia sanctions legislation.
• A second look-up allows user to navigate the various exceptions to Russia trade and transport sanctions.
• The UK government has published a "starter" guide to sanctions, which provides a high-level overview of what sanctions are and how they work.
• A new government page on reporting suspected breaches has also been published.

It has also been announced that the OFSI Consolidated List of Asset Freeze Targets will be closing in January 2026. The single source of UK sanctions designation from that date will be the UK Sanctions List published by the Foreign, Commonwealth & Development Office. Companies should ensure that any screening processes which rely on the OFSI Consolidated List are updated, and discuss with their screening service providers as necessary.

The Office of Trade Sanctions Implementation ("OTSI") has published a blogpost containing a case study on the importance of due diligence in preventing breaches of trade sanctions. The post refers to suspected breach reports submitted to OTSI by a bank in respect of trade in a restricted product from Russia to a third country where payment was routed via the UK branch of the bank. The bank performed enhanced due diligence having identified trade sanctions concerns and did not process the payments. OTSI's post sets out its "key takeaways" from the case in relation to trade sanctions compliance.

OFSI issues additional General Licences

OFSI has issued a number of additional GLs, as summarised below:

• GL INT/2025/7328184 which allows HMRC to make payments into the frozen account of a designated person (under all UK autonomous sanctions regimes, excluding UN designations) and to set off payments against any liabilities of a designated person.
• GL INT/2025/7159960 authorises activity reasonable necessary to effect the receipt or provision of news reporting and journalistic services by a recognised UK news publisher.
• Two GLs (GL INT/2025/7539056 and GL INT/2025/7538856) have been issued to authorise "wind-down" activities with newly designated entities in the energy industries. These GLs are time-limited, expiring in November 2025.
• Certain other GLs have been updated to reflect the designations of Rosneft and Lukoil in particular – companies should therefore carefully check the provisions of any GL on which they wish to rely, and ensure that any reporting and/or record-keeping requirements are met.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.