The UK Government has introduced the Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026 (the “Regulations”), which will come into force on 12 May 2026 (see here). The Regulations introduce Sanctions End-Use Controls (“SEUC”), a new licensing requirement which the UK Government can use to impose licensing requirements on exports where it considers there is a high risk of the goods or related technology being diverted to a sanctioned person or destination. What are Sanctions End‑Use…
On 22 April 2026, the Syria (Sanctions) (EU Exit) (Amendment) Regulations 2026 (the “Syria Amendment Regulations”) came into force, amending the Syria (Sanctions) (EU Exit) Regulations 2019 (the “Syria Sanctions”) to remove trade restrictions relating to luxury goods, gold, precious metals and diamonds. What have the Syria Amendment Regulations changed? The Syria Amendment Regulations have amended UK Syria Sanctions to remove the definitions of “gold, precious metals or diamonds” and “luxury goods” in their entirety.…
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 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…