United Kingdom: Export Controls & Trade & Investment Sanctions

The LNG sector has emerged as a critical battleground for force majeure disputes, shaped by COVID-19, sanctions against Russia, and the Ukraine energy crisis.

The UK government is set to implement sweeping new sanctions on Iran's finance, energy, shipping, and technology sectors, marking a significant expansion of existing restrictions. These measures will bring the UK into closer alignment with EU sanctions and reimpose restrictions previously lifted under the Joint Comprehensive Plan of Action.

Airbus Operations Limited has paid over £6.4 million to HMRC in the highest compound settlement ever reached for strategic export control offences in the UK. The breaches, which AOL self-reported, involved failures to maintain proper records of controlled technology exports and transfers over a sustained period, highlighting the critical importance of robust export control compliance procedures for organizations operating internationally.

The Lloyd's Market Association has introduced a new model clause for marine hull underwriters addressing transit fee demands in the Strait of Hormuz, fundamentally shifting how insurers approach coverage when payments are made to facilitate passage through Iranian territorial waters. This development transforms underwriting focus from navigation risk to sanctions control risk, with significant implications for both insurers and vessel operators navigating these geopolitically sensitive waters.

Welcome to BCL’s latest sanctions round-up, highlighting the key developments in UK and international sanctions

Welcome to BCL’s latest sanctions and export controls round-up, highlighting the key developments in UK and international sanctions

The UK government has introduced significant changes to its sanctions framework, including new powers to target criminal networks, expanded enforcement capabilities...

The UK's HMRC has published comprehensive enforcement statistics covering 2025 and early 2026, revealing the scope and outcomes of sanctions enforcement activities including criminal investigations, goods seizures, and penalty assessments. The data provides insight into how authorities are handling sanctions violations through various enforcement mechanisms, from warning letters to compound penalties exceeding £1 million.

A UK court dismissed sanctions charges against art gallery Hauser & Wirth and logistics company Artay Rauchweger, ruling that prosecutors failed to prove the buyer of luxury artwork was "ordinarily resident" in Russia at the time of sale. The judge determined that evidence of continuing connection to Russia was insufficient to meet the statutory test for ordinary residence under UK sanctions regulations.