On 8th July 2026, the UK enacted the National Security (State Threats) Act 2026 (the new “Act”), introducing a new power for the Home Secretary to designate bodies involved in foreign power threat activity and creating criminal offences for supporting, assisting, or obtaining a material benefit from those bodies. The new regime is intended to address a perceived gap between sanctions, terrorism legislation and the existing National Security Act 2023 framework, by targeting organisations, proxies…
On 15 April 2026, the UK Office of Financial Sanctions Implementation (“OFSI”) published a strategy document setting out its intentions for 2026-29, and marking its 10 year anniversary. The strategy document establishes a framework built around the following pillars: In particular, OFSI has set itself a number of KPIs that signal its direction of travel. In particular, these include the following: OFSI has committed to monitor its progress against the KPIs, and to update where…
On 25 March 2026, the UK Supreme Court issued an important judgment in the case of UniCredit Bank GmbH, London Branch v Constitution Aircraft Leasing (Ireland) / Celestial Aviation Services Ltd [2026] UKSC 10, confirming that a key aspect of the UK’s sanctions framework (namely, the prohibition on providing financial services or funds in pursuance of or in connection with trade in prohibited goods and services) should be interpreted very broadly. The judgment will have far-reaching…
On 9 February 2026, the UK Office of Financial Sanctions Implementation (“OFSI”) published updated financial sanctions enforcement and monetary penalties guidance. This guidance introduces several significant changes to OFSI’s civil enforcement framework, including how OFSI assesses and deals with financial sanctions breaches. These updates to OFSI’s enforcement framework follow OFSI’s consultation on improving civil enforcement processes that took place last year. OFSI recently published a Consultation Response on this, accessible here. These reforms are intended…