On May 1, 2026, President Trump signed Executive Order 14404 (“EO 14404”) entitled “Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security and Foreign Policy,” which significantly expands the US sanctions framework targeting Cuba. EO 14404 imposed a modern US secondary sanctions regime targeting Cuba that is likely to encourage many non-US companies – particularly those with US assets/business and/or reliance on the US financial system –…
On 19 May 2026, the UK Government published the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2026 (SI 2026/543) (the “Amendment Regulations”), introducing numerous amendments to the Russia (Sanctions) (EU Exit) Regulations 2019 (the “Regulations”). The Amendment Regulations introduce certain new trade prohibitions and expand existing controls across the Russia sanctions regime. The Amendment Regulations come into force on 20 May 2026 and, in short, include: Supplementing this, the Office of Trade Sanctions Implementation (“OTSI”) issued…
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 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…