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…
On 28 January 2026, OFSI announced (see here) strengthened multi agency efforts to counter the abuse of cryptoassets for sanctions evasion and related money laundering activities, highlighting increasing operational coordination across the UK enforcement landscape. Multi-agency enforcement through the Crypto Cash Fusion Cell As part of these efforts, OFSI is working with the Crypto Cash Fusion Cell (“CCFC”), a pilot multi‑agency initiative bringing together the National Crime Agency (“NCA”), the Metropolitan Police Service, His Majesty’s…
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…