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…
On 24 February 2026, the UK imposed a wide range of Designated Person restrictions, to mark the fourth anniversary of Russia’s full-scale invasion of Ukraine. In summary, the UK imposed Designed Person restrictions on 240 entities and 7 individuals, and specified 50 ships. The measures are particularly focused on Russia’s energy sector and the “shadow fleet” of vessels. The designations include the following noteworthy parties: The UK Government’s press release for the sanctions is available…
On 25 February 2026, the Swiss Federal Council adopted extensive amendments to the Ordinance on Measures in Connection with the Situation in Ukraine (the “Ukraine Ordinance”), thereby completing the implementation of the EU’s 19th sanctions package against Russia (see press release here). This final step follows the initial implementation step taken on 12 December 2025, when the Swiss Federal Council updated several annexes to the Ukraine Ordinance as a consequence of the same package (see…
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…