On June 23, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and HM Treasury’s Office of Financial Sanctions Implementation (“OFSI”) published a joint statement reflecting on their latest Enhanced Partnership exchange and issued a new joint guidance document that provides a comparative overview of the US and UK sanctions regimes. The joint statement and guidance follow a January 2026 in-person meeting between OFSI and OFAC. The statement and accompanying guidance…
On 28 May 2026, the UK Financial Conduct Authority (“FCA”) published a detailed report outlining steps that financial institutions take to comply with sanctions requirements, including examples of good and poor practice. The report addresses both financial and trade sanctions measures, with financial institutions managing risks arising from their own activities and those of their customers. The report follows the FCA’s engagement with over 150 FCA-supervised firms since February 2022, and builds upon the FCA’s…
On 9 April 2026, the UK Office of Trade Sanctions Implementation (OTSI) announced that, from 27 April 2026, it will assume responsibility for licensing the export of sanctioned goods (and associated ancillary services) to sanctioned destinations (see here). Such licence applications will continue to be made and processed via the Department for Business and Trade’s (DBT) SPIRE system. The change will add to OTSI’s existing responsibilities for licensing sanctioned standalone services (for example professional business…
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…