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
- UK Government amends one entry on UK sanctions list under the Russia regime: On May 23, 2025, the UK Government amended the entry for Michel Litvak on the UK sanctions list under the Russia regime. (https://assets.publishing.service.gov.uk/media/68303b47b33f68eaba953a15/Notice_Russia_230525.pdf).
- UK extends General Licence authorising charity Interim Managers and trustees to make certain payments: On May 21, 2025, the UK Government renewed General Licence INT/2022/1834876, which inter alia authorises interim managers and trustees to make certain payments associated with the basic needs and wind up of a charity, subject to certain terms and conditions. The expiry date of the General Licence has been extended from 30 May 2025 to 30 May 2028. (https://assets.publishing.service.gov.uk/media/682d84f15ba51be7c0f45367/GL_INT_2022_1834876.pdf; GL_CC_Publication_Notice.pdf;).
- UK adds 100 sanctions targets to UK sanctions list under the Russia regime: On May 20, 2025, the UK Government added 100 entries to the UK sanctions list under the Russia regime. According to the UK Government, the latest measures target Russian revenue generating sectors, including energy, communications and financial services, the Russian military industrial complex (RMIC) and its third country suppliers, and malign actors involved in democratic interference and Russia's information war on Ukraine. (UK announces major sanctions in support of Ukraine - GOV.UK; List of Russia sanctions targets, 20 May 2025 - GOV.UK; https://assets.publishing.service.gov.uk/media/682c444f256994af4172ac35/Notice_Russia_200525.pdf).
- UK issues General Licence relating to the wind down of position involving St Petersburg Currency Exchange and JSC Petersburg Settlement Center: On May 20, 2025, the UK Government issued General Licence INT/2025/6275812, which authorises the wind down of transactions involving either St. Petersburg Currency Exchange or Non-bank Credit Organization Joint-Stock Company Petersburg Settlement Center, subject to certain terms and conditions. The General Licence expires on June 19, 2025. (https://assets.publishing.service.gov.uk/media/682c15a802662c6f8ec24470/INT.2025.6275812_GL_2.pdf; https://assets.publishing.service.gov.uk/media/682c15c1256994af4172ac11/INT.2025.6275812_PN.pdf).
- UK issues General Licence relating to processing of payments to the Deposit Insurance Agency: On May 20, 2025, the UK Government issued General Licence INT/2025/6279615, which authorises the processing of payments due to be paid to the State Corporation Deposit Insurance Agency, subject to certain terms and conditions. The General Licence is of indefinite duration. (https://assets.publishing.service.gov.uk/media/682c169d50dbd3ce8372ac1f/INT.2025.6279615_DIA_Permitted_Payments_GL.pdf; https://assets.publishing.service.gov.uk/media/682c16b096a230471ac7e7f4/INT.2025.6279615_PN.pdf).
Israel Sanctions
- Joint statement from the leaders of the United Kingdom, France and Canada on the situation in Gaza and the West Bank: On May 20, 2025, the UK, France, and Canada warned Israel that they will take "concrete actions" if it continues with what they describe as an "egregious" expansion of military operations in Gaza. Sir Keir Starmer, alongside the leaders of France and Canada, urged the Israeli government to "halt its military operations" and to "immediately permit humanitarian aid into Gaza". (Joint statement from the leaders of the United Kingdom, France and Canada on the situation in Gaza and the West Bank - GOV.UK).
ISIL (Da'esh) and Al-Qaida
- UK Government amends 12 entries on and removes one entry from UK sanctions list under the ISIL (Da'esh) and Al-Qaida regime: On May 23, 2025, the UK Government amended 12 entries on and removed the entry for Lionel Dumont from the UK sanctions list under the ISIL (Da'esh) and AL-Qaida regime. (https://assets.publishing.service.gov.uk/media/68303bc7e9440506ee953a2b/Notice_ISIL__Da_esh__and_Al-Qaida_230525.pdf).
Human rights sanctions
- UK Government adds seven entries to UK sanctions list under the Global Human Rights regime: On May 20, 2025, the UK Government added seven entries to the UK sanctions list under the Global Human Rights regime. According to the UK Government, these measures target three individuals, including prominent settler leader Daniella Weiss, two illegal outposts and two organisations that have supported, incited and promoted violence against Palestinian communities in the West Bank. (https://assets.publishing.service.gov.uk/media/682c6a70a4a41a5b3eb00c81/Notice_Global_Human_Rights_200525.pdf; UK sanctions hit West Bank violence network - GOV.UK).
Other Sanctions
- UK amends whistleblowing legislation to strengthen implementation and enforcement of UK sanctions: On May 21, 2025, the Public Interest Disclosure (Prescribed Persons) (Amendment) Order 2025 was laid before Parliament. This Order, which entered into force on June 26, will amend whistleblowing legislation to strengthen the implementation and enforcement of UK sanctions. In particular, the Order prescribes additional matters, including UK sanctions violations, that may be disclosed to: the Secretary of State for Business and Trade, the Secretary of State for Transport, and HM Treasury. (https://www.legislation.gov.uk/uksi/2025/604/article/2/made; https://www.gov.uk/whistleblowing?).
- UK Home Secretary announces plan to introduce new powers to proscribe organisations for state threats: On May 19, 2025, the Home Secretary, Yvette Cooper, announced new powers to address threats from hostile states after three Iranian nationals were charged with spying. The Home Office will introduce legislation allowing the UK to proscribe state-based groups like Iran's Islamic Revolutionary Guard Corps (IRGC) and create related criminal offences. These measures, recommended by terror watchdog Jonathan Hall KC, will be tougher than current laws and specifically target state actors rather than terrorist organisations. The changes aim to strengthen the UK's ability to disrupt and prosecute foreign intelligence operations and those supporting or promoting such entities. (National security update - GOV.UK; https://terrorismlegislationreviewer.independent.gov.uk/wp-content/uploads/2025/05/19.5.25-State-Threat-and-Terrorism-report-1.pdf).
- OFSI investigating 39 potential UK sanctions violations by law firms: On May 16, 2025, it was reported that OFSI is conducting 39 active investigations into law firms suspected of violating UK sanctions, based on information obtained via a Freedom of Information Act request. Data obtained by GIR reveals that OFSI has initiated 123 investigations into law firms since 2021, but only issued a monetary penalty against one. (https://globalinvestigationsreview.com/just-sanctions/article/uk-investigating-dozens-of-law-firms-sanctions-breaches).
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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.
