On 28 May 2026, the UK Financial Conduct Authority (“FCA”) published a detailed report outlining steps that financial institutions take to comply with sanctions requirements, including examples of good and poor practice. The report addresses both financial and trade sanctions measures, with financial institutions managing risks arising from their own activities and those of their customers. The report follows the FCA’s engagement with over 150 FCA-supervised firms since February 2022, and builds upon the FCA’s…
On 19 May 2026, the UK Government published the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2026 (SI 2026/543) (the “Amendment Regulations”), introducing numerous amendments to the Russia (Sanctions) (EU Exit) Regulations 2019 (the “Regulations”). The Amendment Regulations introduce certain new trade prohibitions and expand existing controls across the Russia sanctions regime. The Amendment Regulations come into force on 20 May 2026 and, in short, include: Supplementing this, the Office of Trade Sanctions Implementation (“OTSI”) issued…
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 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…