On 12 December 2025, the Swiss Federal Council announced its decision to significantly expand Switzerland’s sanctions against Iran (see press release here) following a comprehensive revision of the Ordinance on Measures against the Islamic Republic of Iran (“Iran Ordinance”; see link here). With this revision, the Swiss government implemented several recent UN Security Council resolutions, effectively restoring Switzerland’s sanctions regime to the level that existed before 2016. The revision also introduces additional measures relating to…
We are flagging a recent example of continued coordination on sanctions between the United States, United Kingdom, and Australia focused on cybercrime. On November 19, 2025, the United States, United Kingdom, and Australia jointly imposed sanctions on Russia-based bulletproof hosting (“BPH”) service providers Media Land and ML Cloud and 2 of their key personnel after determining they had supported ransomware operations and other cybercrimes. The US OFAC announcement is here, the UK Government announcement is…
On 4 December 2025, the UK Office of Trade Sanctions Implementation (“OTSI”) published a corporate report marking the first year since its launch in October 2024 (see here). Our previous blog post providing more background on OTSI’s powers and jurisdiction can be found here. The corporate report summarises OTSI’s activities during this first year, including licensing and enforcement activity, efforts to engage with businesses, collaboration with international partners and other government functions, as well as…
Global Affairs Canada (GAC) recently released the first formal guidance (Guidance) on compliance with and enforcement of Canada’s economic sanctions regime. This Guidance was issued alongside further updates to GAC’s Frequently Asked Questions. While the Canadian business community has long awaited formal guidance, many interpretive issues remain unresolved. Background Amendments to Canada’s Special Economic Measures Act (SEMA) and Justice for Victims of Corrupt Foreign Officials Act were adopted in 2022 and 2023, which introduced an…