Sanctions tracker – round-up of recent UK sanctions developments

OFSI annual review

OFSI has published its annual review for 2023-2024 providing an overview of its activities in the past financial year. The review provides a summary of OFSI's engagement with industry and international partners over the year, as well as a summary from OFSI of enhancements to financial sanctions implementation over the period, in order to strengthen implementation, intelligence and impact. Of note is a significant increase in OFSI's resourcing – it has increased to 135 FTE staff during the year, split across various functions. The review says that resource in licensing and enforcement teams has increased approximately fourfold, with the guidance and engagement function nearly doubling in size.

This resourcing increase has had some impact on licensing decisions, with OFSI noting an increase in "licensing decisions" from 503 to 1,401. That said, a significant proportion of the resolved cases relate to withdrawn applications, which OFSI has noted include cases where General Licences were issued which rendered the licence application unnecessary, or where multiple licences for the same activity were submitted and then withdrawn.

Some key licensing statistics quoted in the review are set out below:

The majority of specific licences granted (252 out of 379) relate to the Russia regime, with Libya the second most common regime (89 licences).

The review also reports on the outcome of OFSI's annual frozen asset review, which this year identified a total value of £24.4 billion reported to OFSI as frozen. Around £13.4 billion of this relates to the Libya regime, with a further £10.2 billion related to Russia.

As regards OFSI's enforcement activity over the period, the review confirms that 396 cases were recorded over the financial year, and that 242 cases were closed. The review confirms that, as of April 2024, there were 208 cases allocated for investigation.

Of the cases closed during the period, the majority were closed with no further action, either because OFSI determined that there had been no breach (133 cases), or because no decision was made on whether a breach had occurred (61 cases) – in cases of low value and/or severity, the review states that OFSI may determine that undertaking a lengthy investigation and  issuing a determinative outcome would not be proportionate or have a deterrent impact. This suggests that a surprisingly high proportion of the cases reported to OFSI and resolved are cases reported in error and/or very minor breaches.

Where breaches were identified (in 20 cases), the majority (19 out of 20) were dealt with by the issuance of a warning letter, with or without referral to the relevant regulator. The remaining case within the cohort of closed cases was resolved via publication of a disclosure notice.

We assume the cases resolved in 2023-2024 relate primarily to matters reported in earlier periods – consistently with this, the only public enforcement in the period (a Disclosure Notice in August 2023) related to a breach that was self-reported in July 2022. Given that the annual review notes that there were 473 recorded cases in 2022-2023, then notwithstanding the 242 cases closed in 2023-2024, it follows that there may be a significant volume of unresolved cases which have been 'carried over' into the current year. If the 208 cases "allocated for investigation" are largely made up of these cases, then the OFSI enforcement workload looks very substantial, as that does not factor in all of the 396 cases recorded in the 2023-2024 year.

New UK sanctions legislation

The UK has issued the Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2025 (the "Regulations"), which will come into force on 18 April 2025. The Regulations amend various statutory instruments imposing sanctions under the Sanctions and Anti-Money Laundering Act 2018 to reflect changes made by the Economic Crime (Transparency and Enforcement) Act 2022, which introduced an urgent procedure for designations (see our previous briefing for further detail). The Regulations also amend the Venezuela (Sanctions) (EU Exit) Regulations 2019 and the Syria (Sanctions) (EU Exit) Regulations 2019 in relation to the enforcement of trade sanctions, and amend an error in the Republic of Belarus (Sanctions) (EU Exit) Regulations 2019.

OFSI publishes a Disclosure Notice in respect of three charities

On 14 March 2025 OFSI published a disclosure notice regarding three charities: Sahara Hands, Peculiar Peoples’ Palace Ministries, and Impact Planet. This related to the charities' failure to respond to Reqests for Information ("RFI") from OFSI. OFSI stated that it sent letters containing an RFI to each of the charities on three separate occasions using the contact information available on the Charity Commission public register of charities. The charities did not respond to any of the letters or provide the requested information, in breach of the information requirements in the relevant sanctions legislation (the UK's counter-terrorism sanctions regime).

In reaching its decision to publish the disclosure notice, OFSI considered that this breach was not sufficiently serious to justify a monetary penalty. However, the charities' repeated failure to respond to the RFI and lack of mitigating factors warranted a disclosure notice, with the case being assessed as "moderately severe". OFSI added that this was further justified as the charities' failure to respond hindered OFSI's ability to monitor compliance with the relevant sanctions regulations. OFSI emphasised that charities are responsible for updating their contact information and failure to do so will not constitute a mitigating factor when OFSI considers enforcement responses.

General Licences permitting the purchase of petrol for personal use and the payment of arbitration costs

OFSI has issued a new General Licence ("GL") for UK nationals covering petrol purchases. This licence permits payments to Gazprom Neft or its subsidiaries in respect of petrol purchased from petrol stations in Kyrgyzstan and Tajikistan for a UK national's personal vehicle. The GL extends to petrol stations that sell Gazprom Neft's petrol but are not owned by them. The GL also permits "Relevant UK Institutions" to undertake activities reasonably necessary to effect a UK national's purchase of petrol. The GL is effective from 14 March 2025 until 15 March 2027.

On 28 March 2025, OFSI issued a further GL relating to the payment of arbitration costs to arbitrators or arbitration associations. This GL is subject to a requirement to report to OFSI within 30 days of receiving payment under the GL.

OFSI updates financial sanctions FAQs

OFSI has updated its frequently asked questions on financial sanctions, adding a series of FAQs for "relevant firms" who are in scope of sanctions reporting obligations (FAQs 132 to 135). OFSI has also published specific FAQs in relation to high value dealers and art market participants (136 to 138), insolvency practitioners (139) and letting agents (140 to 144). These are largely focused on the types of activities that will bring companies operating in the relevant sectors into the scope of financial sanctions reporting requirements, and on how those reporting obligations will operate in practice. OFSI has also published a factsheet which confirms that high value dealers and art market participants must comply with reporting obligations from 14 May 2025. See our previous post for further detail on this expansion of sanctions reporting obligations to new sectors.

In a further update on 27 March, an additional FAQ (145) was added regarding the use of suspense accounts to freeze assets owned or controlled by designated persons.

New UK designations

On 2 April 2025, the UK's Foreign, Commonwealth & Development Office announced a series of designations under the UK's Global Anti-Corruption regime, including the targeting of a network of pro-Russian actors named Evrazia, operating in Moldova. The UK also designated individuals associated with corruption in Guatemala and Georgia at the same time.

A full list of the newly designated persons can be found in OFSI's notice.