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…
On 10 March 2026, the UK Government published a policy paper outlining the UK’s approach to enforcing sanctions breaches (available here). The policy paper sets out that “[r]obust enforcement of UK sanctions is a priority for this government”. The paper “brings together information on civil and criminal enforcement of sanctions across government departments and agencies”, and “sets out [the UK Government’s] overarching enforcement principles, and details the range of enforcement tools available, along with the…