UK Weekly Sanctions Update - Week Of November 10, 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 issues General Licence permitting continuation of business with Lukoil Bulgaria entities and publishes related FAQ: On November 14, 2025, OFSI issued General Licence INT/2025/7895596, which authorises UK persons to continue business operations and process payments involving Lukoil Bulgaria EOOD, Lukoil Neftochim Burgas AD and their subsidiaries, under the Russia sanctions regime. The general licence expires on February, 14 2026. OFSI also issued FAQ 173 in which OFSI acknowledges the work in Bulgaria to determine the future status of Lukoil Bulgaria's operations and notes that this general licence is valid for three months, but subject to potential renewal based on the aforementioned factual situation. (https://assets.publishing.service.gov.uk/media/69171325eba5bda2026fc998/General_Licence_-_Continuation_of_Business_of_Lukoil_Bulgaria_Entities.pdf; https://www.gov.uk/government/publications/uk-financial-sanctions-faqs/uk-financial-sanctions-faqs).
• OFCOM confirms that it has not used its powers to request information under the Russia regime to date: On November 10, 2025, in response to a freedom of information request, OFCOM, the UK's regulator for communications services, confirmed that it has not to date used its powers to request information under Regulation 77A of the Russia (Sanctions) (EU Exit) Regulations 2019, and that it has not issued any monetary penalties in relation to the provision of internet services to or for the benefit of designated persons. (https://www.whatdotheyknow.com/request/ofcom_and_russia_sanctions/response/3210241/attach/html/10/Ofcom%20and%20Russia%20sanctions.pdf.html).

Other Sanctions

• UK Government publishes Amber Alert on shadow fleet sanctions evasion: On November 14, 2025, the National Crime Agency published an Amber Alert in partnership with OFSI and the FCDO. The alert is intended to raise awareness and share information to support maritime and financial institutions in particular to identify and prevent sanctions evasion involving commodities and financial transactions by networks and shadow fleets that support sanctioned regimes. It includes illustrative case studies involving evasion networks and shadow fleets, as well as a non-exhaustive list of network typology characteristics. (https://www.nationalcrimeagency.gov.uk/who-we-are/publications/769-necc-amber-alert-networks-and-shadow-fleets/file).
• UK Government publishes strategic export control licensing statistics for Q2 2025: On November 13, 2025, the UK's Export Control Joint Unit published its quarterly report on export control licensing statistics for the period April-June 2025. During this period, 2,716 licensing decisions were made for standard inpidual export licences, of which 2,612 (96%) were issued and 104 (4%) were refused. (https://www.gov.uk/government/statistics/strategic-export-controls-licensing-statistics-1-april-to-30-june-2025/strategic-export-controls-commentary-1-april-to-30-june-2025).
• OFSI issues final reminder for frozen assets reporting 2025 - deadline 30 November: On November 11, 2025, OFSI published a final reminder that its annual frozen assets review requires parties to submit a report by November 30, 2025 providing details of all frozen funds or economic resources that are owned, held or controlled by a designated person as at COB September 30, 2025. (https://assets.publishing.service.gov.uk/media/68c2a7e58c6d992f23edd8a5/Financial_Sanctions_Notice__FAR__2025_110925.pdf).

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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.