On 9 April 2026, the UK Office of Trade Sanctions Implementation (OTSI) announced that, from 27 April 2026, it will assume responsibility for licensing the export of sanctioned goods (and associated ancillary services) to sanctioned destinations (see here). Such licence applications will continue to be made and processed via the Department for Business and Trade’s (DBT) SPIRE system. The change will add to OTSI’s existing responsibilities for licensing sanctioned standalone services (for example professional business…
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 4 December 2025, the UK Office of Trade Sanctions Implementation (“OTSI”) published a corporate report marking the first year since its launch in October 2024 (see here). Our previous blog post providing more background on OTSI’s powers and jurisdiction can be found here. The corporate report summarises OTSI’s activities during this first year, including licensing and enforcement activity, efforts to engage with businesses, collaboration with international partners and other government functions, as well as…
On 31 July 2025, the UK Office of Financial Sanctions Implementation (“OFSI”) announced that it had imposed a monetary penalty totalling GBP 300,000 on Markom Management Limited (“MML”), a provider of fiduciary, management, administration, bookkeeping and accounting services incorporated in the UK. The monetary penalty related to conduct in 2018 and a breach of the UK’s pre-Brexit sanctions regime, specifically the UK’s implementing regulations for Council Regulation (EU) No 269/2014 (Ukraine Misappropriation and Human Rights)…