There have been a number of fluctuating developments in the UN and EU’s approach to Iran over the past few weeks, with a further attempt to salvage negotiations in an agreement on 10 September. We set out further details herein, including consideration of the sanctions implications. Political Developments At the end of August, amid concerns regarding Tehran’s continued resistance to international nuclear oversight and Russia’s upcoming presidency of the United Nations Security Council, the E3…
On 31 July 2025, the UK Office of Financial Sanctions Implementation (“OFSI”) announced that it had imposed a monetary penalty totalling GBP 300,000 on Markom Management Limited (“MML”), a provider of fiduciary, management, administration, bookkeeping and accounting services incorporated in the UK. The monetary penalty related to conduct in 2018 and a breach of the UK’s pre-Brexit sanctions regime, specifically the UK’s implementing regulations for Council Regulation (EU) No 269/2014 (Ukraine Misappropriation and Human Rights)…
On 24 April 2025, the UK government published the Syria (Sanctions) (EU Exit) (Amendment) Regulations 2025, which took effect on 25 April 2025 (“Amending Regulations”). These new regulations amend the Syria (Sanctions) (EU Exit) Regulations 2019 to partially suspend a number of significant sanctions that have been in place for over a decade to reflect the developments to the political situation in Syria following the fall of the Assad regime in December 2024. The UK…
On 23 April 2025, the UK government published the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2025, which took effect on 24 April 2025. These new regulations amended the Russia (Sanctions) (EU Exit) Regulations 2019 to introduce additional trade restrictions, focusing on export and import prohibitions, technology, and software transfers. We have set out summaries of the key new measures below. Sectoral Software The amending regulations introduce prohibitions on making available and transferring “sectoral software” to…