The UK’s Office of Financial Sanctions Implementation (OFSI) has introduced The Sanctions (EU Exit) (Miscellaneous Amendment) Regulations 2026 (the “Regulations”), which came into force on 13 May 2026. The Regulations create new powers for the UK government to impose licensing requirements on exports where it considers there is a high risk of the goods or related technology being diverted to a sanctioned person or destination. For further details about the Sanctions End-Use Controls and other…
On 15 April 2026, the UK Office of Financial Sanctions Implementation (“OFSI”) published a strategy document setting out its intentions for 2026-29, and marking its 10 year anniversary. The strategy document establishes a framework built around the following pillars: In particular, OFSI has set itself a number of KPIs that signal its direction of travel. In particular, these include the following: OFSI has committed to monitor its progress against the KPIs, and to update where…
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…
On 13 March 2026, the European Commission published a new set of Frequently Asked Questions (“FAQs”, accessible here) clarifying the scope and application of EU sanctions restrictions on the provision of payment services under Article 5b(2) of Council Regulation (EU) No 833/2014, as amended (the “EU Russia Sanctions”). Article 5b(2) of the EU Russia Sanctions prohibits the provision of certain payment services to Russian nationals and natural and legal persons, entities and bodies in Russia…