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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 the Continuation of Business of Lukoil Bulgaria Entities: On November 20, 2025, OFSI amended General Licence INT/2025/7895596, which authorises UK persons to continue business operations with certain Bulgarian subsidiaries of PJSC Lukoil. In particular, the general licence was extended to cover dealings with Lukoil Aviation Bulgaria EOOD and Lukoil Bunker Bulgaria EOOD. The general licence expires on February, 14 2026. (General_Licence_Lukoil_Bulgaria_INT.2025.7895596.pdf)
- OFSI amends FAQ regarding the continuation of business operations with Lukoil Bulgaria entities: On November 20, 2025, OFSI amended FAQ 173, noting that General Licence INT/2025/7895596 permits the continuation of business with respect to Lukoil Aviation EOOD and Lukoil Bunker Bulgaria EOOD, in addition to the Lukoil Bulgaria entities that were included within the scope of that general licence on November 14, 2025. (UK Financial Sanctions FAQs - GOV.UK
- UK Government adds one entry on the UK Sanctions list under the Russia regime: On November 19, 2025, the UK Government added Aeza Group LLC to the UK sanctions list under the Russia regime. According to the UK Government, this entity has provided 'bulletproof' hosting services to support the work of the Social Design Agency, a Russian disinformation agency sanctioned by the UK in 2024 for its attempts to destabilise Ukraine and undermine democracies around the world. (Notice_Russia_DDMMYY.docx; https://www.gov.uk/government/news/uk-smashes-russian-cybercrime-networks-responsible-for-attacks-on-uk-businesses)
- OFSI updates financial sanctions guidance where licence applications involve Russia divest investors: On November 18, 2025, OFSI updated its general financial guidance to explain when OFSI can grant a divestment licence where a Russian divest investor is involved. In particular, a UK entity applicant can acquire an interest held in a UK entity held by a designated person or the Russian Government if the whole consideration for the acquisition is a transfer of funds to the designated person or the Russian Government and subject to certain other terms and conditions. (UK financial sanctions general guidance - GOV.UK)
Cyber financial sanctions
- UK Government adds six new entries to the UK Sanctions list under the Cyber regime: On November 19, 2025, the UK Government added Alexander Alexandrovich Volosovik, Kirill Andreevich Zatolokin, Yulia Vladimirovna Pankova, Andrei Valerevich Kozlov, Media Land LLC and ML.Cloud LLC to the UK sanctions list under the Russia regime. According to the UK Government, these parties belong to Russian cybercrime networks responsible for attacks on UK businesses. (Notice_Cyber_191125.pdf; https://www.gov.uk/government/news/uk-smashes-russian-cybercrime-networks-responsible-for-attacks-on-uk-businesses)
- UK Government amends one entry on the UK sanctions list under the Cyber regime: On November 19, 2025, the UK Government amended the entry for Chosun Expo on the UK sanctions list under the cyber regime. This entity remains subject to an asset freeze. (Notice_Cyber_191125__Amendment_.pdf)
Other sanctions
- UK publishes Export Control (Amendment) (No. 2) Regulations 2025 updating UK export control regulations: On November 20, 2025, the Export Control Joint Unit (ECJU) published Notice to Exporters 2025/30, which notes updates to the Export Control Order 2008, the assimilated Council Regulation (EC) No 428/2009 of 5 May 2009, and the assimilated Regulation (EU) 2019/125 of 16 January 2019, pursuant to the Export Control (Amendment) (No. 2) Regulations 2025 ("the Regulations"). The amendments update the UK's export control framework to align with international commitments, and to bring the control lists for dual-use items and for goods usable for capital punishment torture in line with changes to the corresponding EU controls. The Regulations will come into force on 16 December 2025. (NTE 2025/30: updates to export control regulations - GOV.UK)
- House of Commons publishes parliamentary briefing on UK and international response to Israel & Palestine: On November 18, 2025, the House of Commons Library published a research briefing that highlighted inter alia sanctions imposed by the UK against organisations and individuals involved in settler violence in the West Bank in May 2025, in addition to the assets freeze and travel ban imposed by the UK, Australia, Canada, New Zealand and Norway against Israeli ministers Ben Gvir and Smotrich in June 2025. (Israel and the Occupied Palestinian Territories in 2025: UK and international response - House of Commons Library)
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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.
