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The final sanctions tracker of 2025 focuses on trade sanctions enforcement and guidance in the first year of OTSI. We also report on a further round of significant financial sanctions designations.
One year of the Office of Trade Sanctions Implementation: OTSI publishes inaugural annual update
On 4 December 2025, the Office of Trade Sanctions Implementation (OTSI), part of the Department for Business and Trade, published its first annual update covering the period 10 October 2024 to 9 October 2025. The update outlines OTSI's licensing and enforcement activity in year one and sets out priorities for 2026.
- OTSI received 146 reports of potential trade sanctions breaches in its first year. While the bulk of those reports came from the financial services sector, 16% came from sectors not subject to mandatory reporting obligations. While no civil monetary penalties have yet been imposed, OTSI confirms several investigations are underway. Referrals have also been made to HMRC and other government partners, and information has been shared with international counterparts under the Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024.
- From early 2026, OTSI will assume responsibility for all export sanctions licensing, except for goods and technology subject to strategic export controls, which will remain with the Export Control Joint Unit. During the period covered by the update, OTSI received 60 licence applications. These were mainly in relation to the provision of professional and business services restricted under the Russia sanctions regime. The average timeframe for receiving an outcome on applications was 82 working days.
- OTSI's stated focuses for 2026 include expanding business support, improving and consolidating guidance, extending outreach across the UK and strengthening proactive enforcement through enhanced intelligence-led monitoring.
Companies will no doubt be watching OTSI's enforcement approach in particular to identify whether any ongoing investigations will result in enforcement action. Financial sanctions enforcement has been on the increase in recent years and so it remains to be seen whether trade sanctions enforcement will follow a similar trajectory.
OTSI guidance on breach reporting
OTSI has also continued its approach of publishing good practice guidance via its blog, with a new post on "what does good breach reporting look like".
This sets out the key information that should be included in any report, key questions that should be answered, and some general dos and don'ts, with the overall message being that OTSI values openness and honesty and welcomes any breach reports.
New Russia-related designations
Outside of the trade sanctions context, the UK has also continued to incrementally expand its Russia-related financial sanctions with further designations in respect of so-called foreign information manipulation and interference operations and on the Russian military intelligence agency (the GRU). The Foreign, Commonwealth & Development Office has also updated its factsheet on the GRU's cyber and information operations.
The UK has also announced a further round of designations targeting the Russian oil industry as well as Central Asian supply chains for cotton pulp. In connection with these new designations, the Office of Financial Sanctions Implementation has issued a new general licence (INT /2025/8202932) which permits the wind-down of transactions with newly designated Russian oil companies PJSC Russneft, PJSC Tatneft, LLC Rusneftegaz Group and LLC NNK-Oil, and their subsidiaries until 31 January 2026.
Sanctions tracker will be taking a festive break but will be back to keep you updated with ongoing sanctions developments throughout 2026. In the meantime, we would like to wish our readers a joyful and restful holiday season, and to extend our sincere thanks for your continued interest and engagement throughout 2025 .
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.
