On 9 February 2026, the UK Office of Financial Sanctions Implementation (“OFSI”) published updated financial sanctions enforcement and monetary penalties guidance. This guidance introduces several significant changes to OFSI’s civil enforcement framework, including how OFSI assesses and deals with financial sanctions breaches. These updates to OFSI’s enforcement framework follow OFSI’s consultation on improving civil enforcement processes that took place last year. OFSI recently published a Consultation Response on this, accessible here. These reforms are intended…
On 28 January 2026, OFSI announced (see here) strengthened multi agency efforts to counter the abuse of cryptoassets for sanctions evasion and related money laundering activities, highlighting increasing operational coordination across the UK enforcement landscape. Multi-agency enforcement through the Crypto Cash Fusion Cell As part of these efforts, OFSI is working with the Crypto Cash Fusion Cell (“CCFC”), a pilot multi‑agency initiative bringing together the National Crime Agency (“NCA”), the Metropolitan Police Service, His Majesty’s…
On 23 January 2026, the European Commission released new FAQ guidance providing clarifications for operators navigating the EU’s expanding Russia sanctions framework. Notably, the European Commission updated their Consolidated FAQs on Sanctions against Russia and Belarus (the “FAQs”, accessible here) with guidance on the Nord Stream transaction ban and the EU’s 19th sanctions package, summarized below. I. Clarifications on the Nord Stream Transaction Ban (Article 5af, Regulation 833/2014) The EU has published dedicated FAQs interpreting…
After publishing a draft implementing decree (Atto del Governo n. 317) (see our previous blog post here), Italy has now approved final legislation (Legislative Decree No. 211 of 30 December 2025) implementing Directive (EU) 2024/1226 which enter into force on 24 January 2026, significantly changing the criminal enforcement landscape in relation to EU sanctions violations. Legislative Decree No. 211/2025 increases criminal liability risks, particularly in respect of EU sanctions compliance, for companies (under Legislative Decree…