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 3 March 2026, the Swiss Federal Supreme Court delivered a notable decision addressing the interplay between foreign sanctions regimes and Swiss law relating to the mandate of Swiss bank PostFinance to ensure access to basic payment services under Swiss public law. PostFinance acted as appellant in the proceeding before the Swiss Federal Supreme Court (the PostFinance Decision is available here; the respective press release published by the Swiss Federal Supreme Court is available here).…
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 10 March 2026, the UK Government published a policy paper outlining the UK’s approach to enforcing sanctions breaches (available here). The policy paper sets out that “[r]obust enforcement of UK sanctions is a priority for this government”. The paper “brings together information on civil and criminal enforcement of sanctions across government departments and agencies”, and “sets out [the UK Government’s] overarching enforcement principles, and details the range of enforcement tools available, along with the…