On 15 October 2025, the UK Office of Financial Sanctions Implementation (“OFSI”) published its 2024-2025 annual review (see here). The report summarises OFSI’s activities for the 2024-2025 financial year and explains that the authority’s work has been centred around three pillars: compliance, capability, and enforcement. We have summarised below some of the key points highlighted in the report. Investigations and Enforcement Licensing Threat Assessment Reports International Collaboration Legislative Enhancements Looking Ahead: Strategy Refresh and 10-Year Anniversary
On 13 October 2025, the Office of Trade Sanctions Implementation (“OTSI”) published a blog post highlighting a recent case involving suspected breach reports from a UK branch of a multinational bank, under the Russia (Sanctions) (EU Exit) Regulations 2019. OTSI’s blog post notes that the UK branch of the bank identified payments linked to the trade of sanctioned goods from Russia to a third country, between April and June 2025. The blog post notes that…
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…
Background Article 8a of Council Regulation (EU) 833/2014 (the “EU Russia Regulations”) imposes obligations on EU parents to undertake “best efforts” to ensure that activities conducted by their non-EU subsidiaries do not undermine EU sanctions targeting Russia and Belarus. This requirement, which was introduced in June 2024, raises complex questions about the scope of EU sanctions and their applicability to the activities of non-EU entities. The Commission previously issued guidance in November 2024 in relation…