ARTICLE
27 March 2026

UK Weekly Sanctions Update - Week of March 23, 2026

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Mayer Brown

Contributor

Mayer Brown is an international law firm positioned to represent the world’s major corporations, funds, and financial institutions in their most important and complex transactions and disputes.
In this weekly update, we summarise the most notable updates in the UK sanctions world.
United Kingdom International Law

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

Central African Republic

  • UK Government updates Central African Republic (CAR) sanctions guidance: On 18 March 2026, the UK Government updated its statutory guidance on CAR sanctions under the Central African Republic (Sanctions) (EU Exit) Regulations 2020 to reflect the Central African Republic (Sanctions) (EU Exit) (Amendment) Regulations 2025, which removed the CAR arms embargo and implemented UN Security Council resolutions. The updated guidance addresses trade sanctions and export provisions that remain in place post-embargo, introduces a new section on director disqualification orders preventing designated persons from serving as UK company directors, and explains the exceptions under Part 6 of the 2020 Regulations, including the UN humanitarian exception. (https://www.gov.uk/government/publications/central-african-republic-sanctions-guidance/central-african-republic-sanctions-guidance)

Other

  • OFSI publishes video guidance on designated persons: On 20 March 2026, OFSI published a video providing an overview of how to find out who is designated under UK sanctions regimes, how OFSI and FCDO come together when there are new designations, and what firms should do once an individual has been designated. (https://www.gov.uk/guidance/ofsi-video-guidance#finding-out-who-is-a-designated-person)
  • OFSI publishes a blog post outlining its updated approach to assessing “reasonableness” when considering licence applications under the UK’s financial sanctions regimes: On 16 March 2026, OFSI noted that some licence applications for legal fees under the legal fees licensing ground involve requests running into millions of pounds, and has emphasised that applicants must demonstrate the reasonableness of such fees. To support its assessment, OFSI will now require an independent Costs Draftsperson's Report where the total legal and Counsel fees exceed £2 million (including VAT) within any six-month period, or £1 million where Counsel is instructed directly. (https://ofsi.blog.gov.uk/2021/06/30/reasonableness-in-licensing/)

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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.

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