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 4 December 2025, the UK Office of Trade Sanctions Implementation (“OTSI”) published a corporate report marking the first year since its launch in October 2024 (see here). Our previous blog post providing more background on OTSI’s powers and jurisdiction can be found here. The corporate report summarises OTSI’s activities during this first year, including licensing and enforcement activity, efforts to engage with businesses, collaboration with international partners and other government functions, as well as…
On 18 July 2025, the European Union adopted its 18th package of sanctions against Russia, including by amending Regulation (EU) 833/2014 and Regulation (EU) 269/2014. The EU also mirrored a number of measures and introduced additional designations in its Belarus sanctions by amending Regulation (EC) 265/2006. Adopted just two months after the 17th package, this latest round of measures reflects the EU’s continued strategic shift toward more dynamic, extraterritorial, and asset-specific sanctions and reinforces the…
On 21 July 2025, the UK government issued the General Trade Licence: Russia Sanctions – Sectoral Software and Technology (the “Sectoral Software Licence”) under Regulation 65 of the Russia (Sanctions) (EU Exit) Regulations 2019 (the “UK Russia Regulations”). The Sectoral Software Licence came into force on 21 July 2025 and will expire on 20 October 2025. The Sectoral Software Licence authorises providers located in or operating from within the UK and UK persons to transfer…