UK Weekly Sanctions Update - Week Of October 27, 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.

Iran sanctions

• UK Government adds one entry to UK Sanctions List under the Iran regime: On October 30, 2025, the UK Government added Aliakbar Ansari to the UK sanctions list under the Iran regime. According to the UK Government, Ansari has played a role in financially supporting the activities of the IRGC. (Notice_Iran_301025.pdf; https://www.gov.uk/government/news/uk-announces-sanctions-against-those-who-fund-the-work-of-the-irgc).
• OFSI amends Interim Necessities General Licence under the Iran regime: On October 28, 2025, OFSI amended General Licence INT/2025/7628424, which authorises certain designated persons to make certain payments to UK Employees and UK Directors and their pensions, relating to the provision of services by IT Providers or accountants in connection with certain operations in the UK, subject to certain terms and conditions. The General Licence was updated to simplify certain definitions and provide further clarity. (https://assets.publishing.service.gov.uk/media/6900cacda6048928d3fc2b19/General_Licence_INT_2025_7628424_Issued_28_10_2025__1_.pdf).

Other sanctions

• OFSI adds FAQ relating to funds allocated by ICSD where corresponding funds were seized and dealt with by the NSD: On October 31, 2025, OFSI issues FAQ 172 which states that an OFSI licence would not be required by a UK financial institution to deal with or receive funds allocated by ICSD that were previously seized by the NSD provided the NSD has no ownership or control over such funds, that the funds are not made available to a designated person and that no other financial sanctions are engaged. (https://www.gov.uk/government/publications/uk-financial-sanctions-faqs/uk-financial-sanctions-faqs).
• ECJU publishes Notice to Exporters detailing the removal of the UK arms embargo on Armenia and Azerbaijan: On October 29, 2025, the ECJU published Notice to Exporters 2025/28, which states that the UK arms embargo on Armenia and Azerbaijan ceased to be in force as of October 13, 2025. (https://www.gov.uk/government/publications/notice-to-exporters-202528-removal-of-uk-arms-embargo-on-armenia-and-azerbaijan/nte-202528-removal-of-uk-arms-embargo-on-armenia-and-azerbaijan).
• OFSI amends General Licence relating to Israel, Palestine and Lebanon humanitarian activity: On October 27, 2025, OFSI amended General licence INT/2023/3749168 which authorises activities necessary to provide humanitarian assistance, other activities that support basic human needs and facilitate the timely provision of those in relation to the conflict in Israel and Palestine, subject to certain terms and conditions. Among other things, the General Licence was extended by two years, the deadline for reporting requirements was amended and certain definitions were updated. (OFSI General Licence - INT/2023/3749168 - GOV.UK).
• UK Government responses to Parliamentary question on insuring vessels transporting Russian oil and gas: On October, 27, 2025, the UK Government responded to a Parliamentary question raised by Lord Impey on whether UK-based insurers are insuring oil or gas tankers that transport Russian fossil fuel products. In response, the UK government notes that UK insurers are permitted to provide insurance products to vessels transporting Russian oil or oil products provided the relevant products are shipped below the Oil Price Cap and subject to the terms and conditions of the Oil Price Cap general licence. The UK Government also notes that, in January 2023, it prohibited all imports of Russian LNG into the UK and the provision of inter alia insurance that would facilitate such imports. (https://questions-statements.parliament.uk/written-questions/detail/2025-10-15/HL11021/).

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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.