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…
From 14 May 2025, certain additional businesses are now subject to mandatory sanctions reporting obligations as changes to the definition of “relevant firms” for financial sanctions reporting purposes come into force. Consequently, High Value Dealers (HVDs), Art Market Participants (AMPs), Letting Agents and Insolvency Practitioners are now legally required to report to OFSI whether they have knowledge or reasonable cause to suspect the presence of sanctioned parties, or suspected financial sanctions breaches. These obligations were…
On January 10, 2025, in a multilateral sanctions action, the US, Canada, EU, and UK sanctioned various Venezuelan individuals linked to the Venezuelan government and prominent state-owned entities. US Sanctions The US Treasury Department’s Office of Foreign Assets Control (“OFAC”) designated eight Venezuelan individuals as Specially Designated Nationals pursuant to Executive Order 13692, including the president of the Specially Designated National state-owned petroleum company, Petroleos de Venezuela, S.A., (PdVSA), the Venezuelan Ministry of Transportation and…
On 10 January 2025, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and the UK’s Office of Financial Sanctions Implementation (“OFSI”) announced the designations of two major Russian oil companies, PJSC Surgutneftegas and Gazprom Neft. The US and the UK have introduced new general licenses to permit limited activity relating to these entities, detailed further below. OFAC also designated numerous energy sector parties and issued a new Russia-related petroleum services prohibition.…