Category: OFSI (UK)

  • Today, Tuesday 5th May, the UK Government has designated the following 12 individuals and 5 entities under the Global Irregular Migration sanctions regime, and designated the following 10 individuals and 8 entities under the Russian sanctions regime.

    Individuals designated under the Global Irregular Migration regime:

    Name:Unique ID:
    Polina Alexandrovna AZARNYKHGIM0051
    Abid Kalid Sharif ABIDGIM0052
    Elena SMIRNOVAGIM0053
    Sergei Vyacheslavovich MERZLYAKOVGIM0054
    Deepak Kumar Taraknath PANDEYGIM0056
    Manjeet SINGHGIM0057
    Suyash MUKUTGIM0058
    Mikhail Sergeevich LYAPINGIM0060
    Dayana Echemendia DIAZGIM0061
    Faisal Abdul Mutallib KHANGIM0062
    Mohammad Sufiyan Dawood Ahmad DARAGURGIM0064
    Rakesh Taraknath PANDEYGIM0065

    Entities designated under the Global Irregular Migration regime:

    Name:Unique ID:
    DREAM HOME TRAVELS AND TOURS LTDGIM0055
    ADVENTURE VISA SERVICES PRIVATE LIMITEDGIM0059
    24×7 RAS OVERSEAS FOUNDATIONGIM0063
    BABA VLOGS OVERSEAS RECRUITMENT SOLUTIONS PRIVATE LIMITEDGIM0066
    O.S.D BROS TRAVELS & VISA SERVICES PRIVATE LIMITEDGIM0067

    Individuals designated under the Russia regime:

    Name:Unique ID:
    Michel Guy France Awana ATEBARUS3498
    Elmir SAIFULLINRUS3499
    Chulpan ISLAMOVARUS3500
    Savsan Ashuraliyevna YUSUPOVARUS3502
    Sergey Nikolaevich KASHCHENKORUS3504
    Mikhail Yurievich VOLOVIKRUS3505
    Egor Valerevich NIKITINRUS3509
    Anastasia BARYSHEVARUS3512
    Konstantin TRIFONOVRUS3513
    Pavel Valerevich NIKITINRUS3515

    Entities designated under the Russia regime:

    Name:Unique ID:
    M9 LOGISTICS (HK) LIMITEDRUS3495
    ELTECH COMPONENT LLCRUS3496
    SEA 2 SKY CO., LTDRUS3497
    CANOPUS TRADING GROUP CO., LTDRUS3501
    TANAQ CO., LTDRUS3503
    M9 LOGISTICS CO., LTDRUS3510
    LLC SNK TRADERUS3511
    ENANGUE HOLDINGRUS3514

    And here are the update files – Global Irregular Migration:

    and Russia:

    , ,
  • UK Gov logo, 50% resolution.png

    Today, Wednesday 29 April, the UK Government has sanctioned 1 individual and varied 3 designations under the Sudan Sanctions Regime. This reflects their addition to the UN Sanctions List on 28 April, pursuant to UN Security Council Resolution 1591 (2005) Sanctions Committee.

    Designated Individual:

    Name:UN ID:Unique ID:
    Al-Goney Hamdan DAGALOSDi.011SUD0036

    Varied Individuals:

    Name:UN ID:Unique ID:
    Alvaro Andres Quijano BECERRASDi.012SUD0026
    Claudia Viviana Oliveros FOREROSDi.013SUD0028
    Mateo Andres Duque BOTEROSDi.014SUD0029

    Furthermore, the UK Government has varied 17 designations sanctioned under the Afghanistan Sanctions Regime. The reflects amendments made to the UN Sanctions List on 28 April, pursuant to UN Security Council Resolution 1988 (2011) Sanctions Committee.

    Varied Individuals:

    Name:UN ID:Unique ID:
    Abdul Kabir MOHAMMAD JANTAi.003AFG0007
    ABDUL MANSURTAi.007AFG0011
    FAZL MAZLOOMTAi.023AFG0023
    ABDUL QULTAi.027AFG0027
    ABDUL BAQI AWAL SHAHTAi.038AFG0034
    DIN HANIFTAi.043AFG0038
    HAMDULLAH NOMANITAi.044AFG0039
    NOORUDDIN QASIMTAi.058AFG0046
    MOHAMMAD AKHUNDTAi.060AFG0047
    NAJIBULLAH HIDAYATULLAHTAi.071AFG0055
    ABDUL-HAQ WASSIQTAi.082AFG0062
    KHAIRULLAH KHAIRKHWAHTAi.093AFG0071
    NOOR SAQIBTAi.110AFG0088
    HAMIDULLAH SHER MOHAMMADTAi.118AFG0092
    Azizirahman ABDUL AHADTAi.121AFG0094
    SIRAJUDDIN HAQQANITAi.144AFG0112
    AHMAD AGHATAi.156AFG0122

    The UK Government has also varied the designation of 1 individual sanctioned under the Russia Sanctions Regime.

    Varied Individual:

    Name:Unique ID:
    Kantemir Kaparbekovich CHALBAYEVRUS2990

    Here are the OSFI Notices – Sudan:

    Afghanistan/Taliban:

    and Russia:

    The email also included links to the UNSC (United Nations Sanctions Committees) press releases, which are included or referenced here in their own post, so why duplicate them?

  • Office of Financial Sanctions Implementation HM Treasury

    General Licence INT/2026/9512597 issued and 1 FAQ added, 1 FAQ withdrawn and 2 FAQs amended

    On 24 April 2026, the General Licence INT/2026/9512597 was issued. The General Licence pertains to legal Services which will take effect following the expiry of Legal Services General Licence INT/2025/7323088 on 28 April 2026.

    Any persons intending to use General Licence INT/2026/9512597 should consult the copy of the Licence for full details of the definition, permissions, and usage requirements.

    FAQ 170 was withdrawn and FAQ 184 was added following the new General Licence. FAQ 50 and FAQ 57 were amended.

    Don’t want to click? Here’s the new General License’s Publication Notice:

    and the General Licence:

    the new FAQ:

    Legal Services General Licence (INT/2026/9512597) 

    184. The Legal Services General Licence has been updated and is available online. What has changed and what does this mean for law firms, legal advisors, Counsel and providers of Expenses?

    General Licence INT/2026/9512597 refreshes the fees and expenses caps for Parts A and B for the six-month period from 29 April 2026 until 28 October 2026, when the licence expires.

    In addition to refreshing the caps, OFSI has also made some amendments to the General Licence.

    General Licence INT/2026/9512597 introduces a new definition:

    ‘DP Group’ means a DP designated for the purposes of an asset freeze by the UK under the UK Autonomous Sanctions Regulations, excluding those designated for the purpose of compliance with United Nations obligations, together with any entities owned or controlled by that DP.

    Several permissions and conditions of the General Licence have been amended to incorporate this definition. Please consult the full licence online.

    A DP and its owned or controlled entities may pay the legal fees for that DP or another entity within that DP group.

    The Licence fee and expenses caps apply to all matters that a Law Firm (or Counsel, if engaged under a direct instruction) are handling for individuals or entities within a DP group, or, where there is no DP Group, for the designated entity or individual.

    General Licence INT/2026/9512597 has also been amended to permit payments to a Non-UK Bank Account held by an individual regulated by the Solicitors Regulation Authority, the Law Society of Scotland or the Law Society of Northern Ireland, who provides Legal Services outside the United Kingdom, otherwise than at a branch of a Law Firm that falls within paragraph 8.2.1 (Part A) or 11.2.1 (Part B). Please consult the full licence for the complete permission.

    Added on: 24 April 2026

    and the amended ones:

    Legal Services General Licence (INT/2024/5334756)

    50. How do the fees and expenses caps apply? Is it per DP (i.e., for all a DP’s matters across all law firms) or is it per law firm being instructed by a DP? 

    OFSI has amended the General Licence so the £2,000,000 caps for each of Parts A and B, and the related expenses caps, now apply to each law firm instructed by the DP Group, or where there is no DP Group, to the designated entity or individual.  

    The caps cover all the matters being handled by that law firm for the DP Group, or where there is no DP Group, to the designated entity or individual. This means that the caps do not apply to each individual matter handled by that law firm.

    Amended on: 24 April 2026

    Scope of Legal Services General Licence 

    57. Can an entity owned and/or controlled by a designated person (DP) pay the DP’s legal fees even though the entity did not explicitly receive the legal advice? 

    Yes, provided the conditions of the General Licence are met. The General Licence states at paragraph 5 that a DP may pay professional legal fees, Counsel’s fees, and/or Expenses to a Law Firm, a Legal Adviser, Counsel or a provider of Expenses for Legal Services which have been provided to that DP or to any other DP in the same DP Group.”

    The General Licence defines a DP as “those individuals or entities designated (or owned or controlled by an individual or entity designated) … excluding those designated for the purpose of compliance with United Nations obligations.”

    Please see related FAQ 50.   

    Amended on: 24 April 2026

  • Office of Financial Sanctions Implementation HM Treasury

    Upcoming changes to UK sanctions regulations 

    We are writing to give you advance notice of forthcoming changes made by the Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026. The regulations will come into force on the 12th May.

    What’s changing

    Changing relevant firms reporting from euros to pounds

    • Across all UK sanctions regulations, the definitions of high value dealers and art market participants within the relevant firms regulations are being updated so that monetary thresholds are expressed in pounds sterling (£) rather than euros (€). In particular, the €10,000 threshold is being replaced with a £10,000 threshold.
    • This aligns sanctions reporting obligations with upcoming changes to those in the UK money laundering regulations, so firms are not reporting in two different currencies.

    Electronic notices for licences

    • The law is being updated to confirm that OFSI and other authorities can send notices for licences electronically without needing consent for this approach. This reflects how communications already work and removes an outdated technical requirement.

    HM Treasury debt exception

    • A clarification that the exception for Treasury debt applies to all transfers of funds across the entire payment chain, including intermediaries.

    Updates to the prior obligations licensing ground

    • The SI broadens the prior obligations licensing ground, giving OFSI greater flexibility to license legitimate pre-designation obligations in appropriate cases while maintaining safeguards against sanctions circumvention.

    Further information can be found here

    Here’s that “further information”:

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  • I asked Claude to explain:


    General Licence INT/2025/7628424 — Plain English Summary

    What is this, and why does it exist?

    This is a UK financial sanctions licence issued by OFSI (the Office of Financial Sanctions Implementation, part of HM Treasury). It was granted under Regulation 40 of the Iran (Sanctions) (Nuclear) (EU Exit) Regulations 2019 — the UK’s domestic legal framework for Iran-related nuclear sanctions.

    Under those sanctions, certain Iranian banks and their UK subsidiaries are “Designated Persons” (DPs) — meaning their assets are frozen and financial transactions involving them are normally prohibited. But a total freeze creates a practical problem: these entities still have UK staff, UK office costs, and UK legal obligations. This licence is the solution. It carves out a narrow, carefully controlled set of payments that are permitted despite the freeze.


    Who are the “Designated Persons” covered?

    The licence names five entities in Annex 1: Bank Melli (including Melli Bank PLC), Bank Saderat Iran, Bank Tejarat, Persia International Bank Plc, and Iran Insurance Company. These are the Iranian-linked financial institutions with a UK presence that the licence applies to.


    What does the licence actually allow?

    The DPs, or persons acting on their behalf, may make payments for:

    • Staff pay: remuneration, allowances, and contractual or statutory redundancy payments to UK employees and UK directors;
    • Pensions of UK employees and UK directors;
    • IT services: fees and costs for UK providers of broadband, telephone, email, anti-virus/cybersecurity software, operating system software, and regulatory reporting software; and
    • Accountancy services: fees for UK chartered or certified accountants for the DPs’ UK operations.

    In short: the frozen entities can still pay their UK-based staff, keep their IT running, and meet their accountancy obligations — but nothing more.


    Key safeguards and conditions

    All payments may only be made to accounts held at a regulated UK financial institution (a “Relevant Institution”).

    Payments must not be made, directly or indirectly, to any Designated Person. So the money can flow to ordinary UK employees and suppliers, but not back into frozen accounts.

    Within 14 days of the end of each calendar month, the UK branch of the DP must send a report to HM Treasury detailing every payment made that month — including who sent and received the money, the purpose, the amount, the payment route, and the date.

    All parties must keep accurate records for a minimum of six years.


    Duration and today’s update

    The licence took effect on 23 October 2025 and, as updated today (16 April 2026), expires at 23:59 on 22 October 2026 — the update today appears to have extended the expiry date by six months, from 22 April 2026 to 22 October 2026. This is consistent with the typical OFSI practice of rolling such licences forward in six-month blocks.


    🔍 Transparency: What is and isn’t supported by my sources

    ClaimSource support
    Licence issued under Iran Nuclear Regulations✅ Directly from the licence text
    Five named DPs in Annex 1✅ Directly from the licence text
    Four categories of permitted payments✅ Directly from the licence text
    Reporting and record-keeping requirements✅ Directly from the licence text
    Extension today to 22 October 2026✅ The fetched PDF (updated 16 April 2026) shows this date, replacing the earlier 22 April 2026 expiry
    The reason for today’s update (i.e., why it was extended, not just that it was)⚠️ Not stated in the licence text or any source I found. OFSI does not typically explain renewals. This is an inference based on the changed expiry date.
    Previous amendment history (Oct/Dec 2025)✅ Confirmed by both the licence text and Mayer Brown’s sanctions update

    If you need to act on this licence — for example, if you are one of the named banks or are providing services to them — you should consult the official GOV.UK page and consider seeking specialist sanctions law advice, as I am not a lawyer and the licence text itself notes that full details govern over any summary.

    These sort of explanations almost makes sanctions compliance easy… almost.

  • Office of Financial Sanctions Implementation HM Treasury

    OFSI General Licence INT/2025/7628424 amended

    On 16 April 2026, the General Licence INT/2025/7628424 was amended as:

    The definition of “IT Providers” was amended and now reads:

    • “UK providers of broadband services, telephone services, email services, anti-virus and cybersecurity software services, operating system software services and regulatory reporting software.”

     Permission 4.2 was added to the licence:

    • 4.2 Where a payment is made by a Person acting on behalf of one of the DPs in accordance with paragraph 4.1, the DP may repay the Person the same amount as the payment provided payment is made from a UK account.

    Permissions 8.2 and 8.3 were added to the licence:

    • 8.2 Process currency conversions and deduct reasonable fees as appropriate when processing payments under paragraph 4 on behalf of one of the DPs; and
    • 8.3 Transfer funds between different currency accounts held by one of the DPs in order to effect any conversion required under paragraph 8.2.

    Reporting requirement 10.1 was amended to reflect the new permission 4.2:

    • 10.1 The name of the DP sender or the Person making the payment on their behalf; and

    The licence was extended by six months and now expires on 22 October 2026.

    Any persons intending to use General Licence INT/2025/7628424 should consult the copy of the Licence for full details of the permissions and usage requirements.

    Here’s the updated Publication Notice:

    and the updated General Licence:

    Fun fact: I see that these files do not follow the same file naming convention as others I’ve uploaded recently….

    , ,
  • UK Gov logo, 50% resolution.png

    Today, 16 April, the UK government varied 1 entity and 2 individuals under the Afghanistan sanctions regime and corrected 1 entity under the Global Human Rights regime

    Entities Varied:

    NameUnique ID
    HAJI KHAIRULLAH HAJI SATTAR MONEY EXCHANGEAFG0001

    Individuals Varied:

    NameUnique ID
    Khalil Ahmed HAQQANIAFG0118
    Abdul Rauf ZAKIRAFG0130

    Entities Corrected:

    NameUnique ID
    BSQUARE TECHNOLOGY CO. LTDGHR0183

    (remember, those links are to FCDO’s UK Sanctions List pages for those parties – and the Download button makes a nice ODT document you can open in the word processor of your choice)

    Here’s OSFI’s Afghanistan/Taliban notice:

    and the Global Human Rights one:

    and, once more, here’s our recent blog post on the UN action, which includes a link to the press release.

  • OFSI today published its 2026-2029 strategy – and summarized it in a blog post:

    OFSI Strategy 2026-29

    This year marks ten years since the Office of Financial Sanctions Implementation (OFSI) was established.  

    Over the last ten years, OFSI has built stronger capability and confidence, enhancing licensing, enforcement and intelligence, deepening international partnerships, and supporting firms to navigate increasingly complex sanctions regimes. 

    This Strategy marks the start of OFSI’s second decade, setting out an ambitious agenda for 2026–29 to keep UK financial sanctions effective, resilient and impactful. 

    At its heart is the new, clear operating model: we will Promote, Enable, Respond and Change (PERC).  

    • Promote: make sanctions rules and expectations clearer, so compliance is the norm and non-compliance has visible consequences. 
    • Enable: reduce friction for legitimate activity through practical guidance, strong licensing service standards and digital-first services. 
    • Respond: act quickly and proportionately on breaches, using the full enforcement toolkit to deter and disrupt non-compliance and circumvention. 
    • Change: embed lasting improvements by learning from cases and engagement, strengthening sanctions design and driving sustained compliance cultures. 

    We will focus our policy and operational decisions—and our resources—on the areas of greatest impact, grounded in high-quality data, evidence and a stronger understanding of threats, risks and context. We will deliver timely and proportionate licensing, proactive and impactful enforcement, robust and targeted counterterrorism designations, and focused compliance support in our highest impact areas.  

    We will maintain open, regular engagement with industry to understand how sanctions are operating in practice and to make compliance as clear and workable as possible. We will provide more direct support to industry, to support compliance and reduce friction across the system. We will use a feedback-loop approach: insights from firms’ queries, licensing applications, compliance challenges and suspected breach reporting will inform where we target guidance, which scenarios we prioritise for clarification, and how we design and improve our services. In turn, we will feed learning back to industry through timely updates—such as blogs, FAQs, guidance and lessons learned from enforcement—so that firms can strengthen controls, reduce repeat issues and respond quickly to emerging risks. 

    We will work in close partnership across government, with regulators and law enforcement, and with the private sector and international allies to strengthen the impact of UK financial sanctions and support effective compliance. We will use structured engagement and information-sharing to build a shared understanding of emerging risks and circumvention typologies, align expectations and guidance where possible, and coordinate action to reduce arbitrage and close gaps. Through these partnerships, we will improve the quality of compliance support, target our operational activity more effectively, and amplify the deterrent effect of enforcement. 

    The Strategy sets out Key Performance Indicators (KPIs) against which we will monitor our progress under the Strategy. We will report against these in our Annual Review starting with the next publication this Autumn.  

    And here’s the strategy:

    ,
  • Claude explains it all, and checks its work – with some light editing to remove some of the details of my prompt:

    General Licence INT/2026/9491628, issued by OFSI — the Office of Financial Sanctions Implementation, a unit of HM Treasury – today. The licence was issued under the Global Human Rights Sanctions Regulations 2020 and allows for insolvency-related payments and activities connected with the Prince Group and their subsidiaries, subject to conditions.

    In plain terms: the Prince Group and its associated people and companies have been hit with UK financial sanctions — meaning their assets are frozen and doing business with them is normally illegal. This licence is a carefully bounded exception that allows bankruptcy/insolvency proceedings to go forward despite those sanctions.


    Who Is the Prince Group?

    The Prince Group is a high-profile, multi-billion-pound conglomerate with extensive business activities across Cambodia and beyond.

    In October 2025, the UK and US governments jointly sanctioned a network operating illegal scam centres across Southeast Asia. The UK and US designated the Prince Group as a transnational criminal organisation, accusing its chairman, Chen Zhi, of directing forced-labour “scam compounds” in Cambodia that used human trafficking victims to carry out cryptocurrency fraud, including “pig butchering” schemes — a form of fraud where victims are lured into fake romantic relationships and gradually convinced to invest large sums in fraudulent cryptocurrency platforms.

    The UK’s statement of reasons says there are reasonable grounds to suspect Prince Group is responsible for engaging in, facilitating, or supporting human rights abuses; providing financial services knowing they may contribute to human rights abuses; and profiting financially from human rights abuses — specifically, the operation of scam centres in Cambodia involving forced or compulsory labour.

    As a result of the October 2025 sanctions, a £100 million office block in the City of London, two multi-million-pound mansions, and a helicopter were frozen.

    Earlier in 2026, Cambodia arrested and extradited Chen Zhi to China to face charges of masterminding a multi-billion-dollar cyber-fraud empire. He had his Cambodian citizenship revoked by royal decree prior to his expulsion.


    What the Licence Actually Does

    When a company is sanctioned, its assets are frozen — which creates a legal problem for insolvency proceedings, because those proceedings inherently involve moving money around (paying creditors, selling assets, etc.). This licence solves that problem.

    The licence lists thirteen “Prince Group DPs” (designated persons) — the Prince Group Global Group Ltd itself, plus twelve related individuals and companies including Chen Zhi, and entities such as Byex Exchange Company Limited, BSquare Technology Co. Ltd., and Tian Xu International Technology PLC.

    Under the licence, any person (including an insolvency practitioner), designated person, or subsidiary may carry out “Permitted Insolvency Activities,” and a Relevant UK Financial Institution may process payments made in connection with those activities.

    The key constraint is significant: permitted insolvency activities include making, receiving, or processing payments and any other action in connection with insolvency proceedings — provided this does not result in funds or economic resources being made available directly or indirectly to or for the benefit of any designated person or subsidiary, save where such funds are ultimately held in a frozen account or treated as frozen.

    In other words: money can move through the insolvency process, but it cannot end up back in the pockets of the sanctioned parties. Any funds recovered must remain frozen.

    The licence took effect on 14 April 2026 and expires at 23:59 on 13 April 2031 — a five-year window.


    Source Transparency

    Directly sourced from the PDF itself (primary source):

    • All details about the licence number, date, definitions, list of designated persons, permissions, conditions, and duration.

    Sourced from UK government publications (GOV.UK and related official documents):

    • The sanctions designation details and the UK’s statement of reasons for designating the Prince Group (from the October 2025 Financial Sanctions Notice published on publishing.service.gov.uk).
    • The October 2025 joint UK/US announcement (gov.uk press release).

    Sourced from OCCRP (investigative journalism):

    • Details on the March 2026 widening of sanctions, the frozen London properties, Chen Zhi’s extradition to China, and Li Thet’s London penthouse seizure.

    Sourced from Khmer Times:

    • The scale of the “#8 Park” compound (reportedly capable of holding up to 20,000 workers) and Xinbi’s $19.9 billion in transactions — these figures originate from FCDO statements and Chainalysis data cited in those articles, not independently verified here.

    Not directly supported by my sources:

    • The internal operations of the insolvency proceedings themselves (who the insolvency practitioner is, what assets are involved, which jurisdiction is primary) — the licence notice doesn’t specify these, and I found no public reporting on them. The licence’s existence implies proceedings are underway or imminent, but the details are not public from what I could find.
    • Whether Prince Group entities have meaningful UK-registered assets beyond the properties already publicly reported — the licence covers subsidiaries “incorporated anywhere in the world,” suggesting the proceedings may span multiple jurisdictions.
  • Office of Financial Sanctions Implementation HM Treasury

    New OFSI General Licence INT/2026/9491628 issued

    On 14 April 2026, the General Licence INT/2026/9491628, Prince Group and their Subsidiaries – Insolvency related payments and activities was issued which allows for insolvency-related payments and activities connected with the Prince Group and their Subsidiaries, subject to conditions.

    Any persons intending to use General Licence INT/2026/9491628 should consult the copy of the Licence for full details of the permissions and usage requirements.

    Here’s the General License’s Publication Notice:

    and the General Licence itself: