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 28 August 2025, France, Germany, and the United Kingdom (the “E3”) formally triggered the “snapback” mechanism under the Joint Comprehensive Plan of Action (“JCPOA”), citing Iran’s continued non-compliance with its nuclear-related commitments. This move has been followed by weeks of unsuccessful negotiations at the United Nations aimed at extending the JCPOA framework. As a result of the snapback, and the failure to reach an agreement, all UN sanctions previously lifted under the JCPOA have…
On 30 September 2024, the UK Government issued a notice stating that from 31 October 2024, the provision of intra-group services will no longer be a specific licensing ground available in relation to professional and business services provided by UK companies to their Russian subsidiaries. Licence applications submitted before 31 October 2024 will not be affected by the change. Under Regulation 54C of The Russia (Sanctions) (EU Exit) Regulations 2019 (“UK Russia Regulations”), it is prohibited…