On 25 June 2026, the UK’s Export Control Joint Unit (“ECJU”) introduced a new Open General Export Licence for dual-use items (“Dual-Use OGEL”) intended to simplify licensing requirements for UK exporters of dual-use items by providing a single, streamlined licensing process for exports to certain low-risk destinations. The Dual-Use OGEL entered into force immediately upon its publication. The Dual-Use OGEL consolidates two existing licences (the EU Member States Dual-Use OGEL and General Export Authorisation (GEA)…
On 28 May 2026, the UK Financial Conduct Authority (“FCA”) published a detailed report outlining steps that financial institutions take to comply with sanctions requirements, including examples of good and poor practice. The report addresses both financial and trade sanctions measures, with financial institutions managing risks arising from their own activities and those of their customers. The report follows the FCA’s engagement with over 150 FCA-supervised firms since February 2022, and builds upon the FCA’s…
On 25 March 2026, the UK Supreme Court issued an important judgment in the case of UniCredit Bank GmbH, London Branch v Constitution Aircraft Leasing (Ireland) / Celestial Aviation Services Ltd [2026] UKSC 10, confirming that a key aspect of the UK’s sanctions framework (namely, the prohibition on providing financial services or funds in pursuance of or in connection with trade in prohibited goods and services) should be interpreted very broadly. The judgment will have far-reaching…
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…