On 15 October 2025, the UK Office of Financial Sanctions Implementation (“OFSI”) published its 2024-2025 annual review (see here). The report summarises OFSI’s activities for the 2024-2025 financial year and explains that the authority’s work has been centred around three pillars: compliance, capability, and enforcement. We have summarised below some of the key points highlighted in the report. Investigations and Enforcement Licensing Threat Assessment Reports International Collaboration Legislative Enhancements Looking Ahead: Strategy Refresh and 10-Year Anniversary
In significant parallel actions this week, the EU and US imposed new sanctions on Russia. While the EU’s 19th sanctions package is much broader in scope, the measures overlap in their focus on the Russian energy sector, with the US imposing full blocking sanctions on Russia’s two largest oil majors, OJSC Rosneft Oil Company (“Rosneft”) and Lukoil OAO (“Lukoil”) and the EU imposing a full ban on Russia-origin liquified natural gas (“LNG”), among other energy sector…
On 13 October 2025, the Office of Trade Sanctions Implementation (“OTSI”) published a blog post highlighting a recent case involving suspected breach reports from a UK branch of a multinational bank, under the Russia (Sanctions) (EU Exit) Regulations 2019. OTSI’s blog post notes that the UK branch of the bank identified payments linked to the trade of sanctioned goods from Russia to a third country, between April and June 2025. The blog post notes that…
Following the EU’s 18th sanctions package and the latest developments of the UK’s sanctions against Russia, the Governments of Australia and Japan also introduced additional measures against Russia respectively on 18 and 12 September 2025. Among other measures, they have agreed with other G7 countries to phase out Russian oil imports in response to the 2022 invasion of Ukraine, indicating aligned efforts within the G7 with respect to the imposition of sanctions against Russia. This…