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…
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…