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…
On 21 January 2026, the EU’s restrictions on the import of refined petroleum products deriving from Russian-origin crude oil entered into force. The restrictions, introduced as part of the EU’s 18th package of sanctions targeting Russia under Article 3ma of EU Regulation 833/2014 (as previously summarised in our blog post here), prohibit the direct or indirect purchase, import or transfer into the EU of refined petroleum products obtained from third countries that derive from Russian-origin…
On 15 January 2026, the EU applied its new automatic and dynamic adjustment mechanism to the Oil Price Cap (“OPC”) on seaborne Russian crude oil, reducing the cap from USD 47.60 to USD 44.10 per barrel, effective 1 February 2026. The mechanism ensures that the OPC remains 15% below the average Urals crude market price over a rolling 22‑week period. On the same day, the UK confirmed that it would lower its OPC to USD…
The EU and UK have recently updated their respective lists of items subject to dual-use export controls, introducing important changes covering emerging technologies. In this blog post, we summarise the key updates under both the EU and UK regimes, and we highlight key steps that exporters can take in response to the changes. EU updates to the EU Dual-Use Regulation On 14 November 2025, the EU published Delegated Regulation (EU) 2025/2003, amending Annex I of…