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…