Today, Tuesday 14 April, the UK Government has amended the designations of the following 4 individuals sanctioned under the Afghanistan Sanctions Regime. This reflects the decision to amend these designations made by UN Security Council Sanctions Committee pursuant to Resolution 1988 (2011) on 13 April.
Furthermore, an administrative amendment has been made to 1 entity sanctioned under the Global Human Rights Sanctions Regime.
Why did OFSI extend the expiration date of General Licence INT/2026/8893924 until July 8th?
The initial response:
The Office of Financial Sanctions Implementation (OFSI) extended the expiration date of General Licence INT/2026/8893924 (the “Maritime Mutual Re-Insurance Wind Down” licence) to July 8, 2026, primarily to provide additional time for the orderly winding down of complex insurance and reinsurance contracts.
The extension, which was announced on April 9, 2026 (the original expiry date), follows several key factors:
1. Complexity of Maritime Insurance
Maritime Mutual entities were designated on February 24, 2026, as part of a major sanctions package targeting Russia’s “shadow fleet.” Because insurance and reinsurance policies—particularly Protection and Indemnity (P&I) cover—involve long-tail liabilities and intricate regulatory requirements, the initial six-week wind-down period proved insufficient for UK insurers and brokers to legally exit or transfer these contracts.
2. Industry Feedback
The extension likely responds to feedback from the London insurance market and global maritime stakeholders. Winding down cover for hundreds of vessels simultaneously requires time to:
Identify all underlying risks.
Process necessary cancellations and premium refunds.
Ensure that vessels have sufficient time to seek alternative, compliant cover to meet international maritime conventions.
3. Orderly Market Exit
By extending the deadline to July 8th, OFSI aims to mitigate the risk of accidental breaches and prevent immediate, disorderly disruptions in the maritime sector. The licence permits UK persons to receive, process, and transmit funds or economic resources to “extricate themselves” from contracts written prior to the February 24th designation.
Key Details of the Licence
Feature
Details
Licence Reference
INT/2026/8893924
Entities Involved
Maritime Mutual Association Limited (Gibraltar), Maritime Mutual Insurance Association (NZ) Limited, and their subsidiaries.
Current Expiry
23:59 on July 8, 2026
Permissions
Winding down, cancelling, or terminating insurance/reinsurance contracts agreed in writing before Feb 24, 2026.
… you might find it interesting that this extension coincides with a broader OFSI effort to manage the high volume of licensing applications, which reached over 900 in the previous fiscal year.
This looked reasonable, but I was curious as to what Gemini was inferring rather than knowing. So…
provide a source list for your response. Is any part of your response not supported by the sources?
And here’s Gemini checking its work:
My previous response was based on official UK government updates and industry analysis typical of such sanctions developments. Below is the source list and a breakdown of what is explicitly stated versus what is inferred based on regulatory context.
Source List
Office of Financial Sanctions Implementation (OFSI):
Publication Notice: General Licence – INT/2026/8893924 (Amended April 9, 2026).
General Licence INT/2026/8893924: Maritime Mutual Re-Insurance Wind Down (Full text, updated version).
Designation entries for Maritime Mutual Association Limited and Maritime Mutual Insurance Association (NZ) Limited (February 24, 2026).
Legal & Industry Trackers (Secondary Sources):
Ashurst Russia Sanctions Tracker (UK): Update for April 2026 detailing the extension of wind-down periods.
LexisNexis Corporate Crime Highlights: Entry dated April 9, 2026, regarding the Maritime Mutual extension.
Insurance Business Mag: “Maritime Mutual added to UK Russia sanctions list” (February 26, 2026), providing context on the “shadow fleet” and P&I cover.
Support Analysis
While the primary facts are strictly supported by the official record, the qualitative “reasons” for the extension involve a degree of synthesis.
Part of Response
Supported by Sources?
Note
New Expiry (July 8, 2026)
Yes
Explicitly stated in the amended GL and Publication Notice (April 9, 2026).
Announcement Date (April 9)
Yes
The date the amendment was published on GOV.UK.
Designation Context (Feb 24)
Yes
Matches the date Maritime Mutual was added to the UK Sanctions List.
Reasons: “Complexity” & “Industry Feedback”
Partial
OFSI notices are typically technical; they rarely list “industry feedback” in the text of the licence itself. However, these are the standard justifications cited by legal experts (e.g., Ashurst, Baker McKenzie) and are consistent with OFSI’s “Reasonableness in licensing” policy published in March 2026.
“Shadow Fleet” Mention
Contextual
This is the official reason for the original designation (supporting Russian energy exports via non-compliant vessels), but the extension notice doesn’t repeat this—it only references the DP (Designated Person).
Is any part not supported?
The specific claim that the extension was due to “London insurance market feedback” is an expert inference. While historically true for almost all OFSI maritime insurance extensions (like the previous LUKOIL or GTLK wind-downs), the April 9th publication notice for INT/2026/8893924 technically only lists the amendment to the date without a detailed “Statement of Reasons” for the extension itself.
Call for evidence on ownership and control in financial sanctions regulations
OFSI has extended the deadline for its call for evidence on how UK financial sanctions regulations on ownership and control are applied in practice. The call for evidence will now close at 11:59pm on Monday 20th April 2026.
We have extended the deadline to allow firms and other stakeholders more time to prepare and submit evidence, including practical examples from real cases.
The Call for Evidence seeks industry views on how the ownership and control test is applied in practice, including where firms face challenges. The test is designed to stop designated persons from sidestepping UK sanctions by hiding behind complex company structures, trusts or proxies. However, assessing the ability of a designated person to control an entity — even if they are not actively doing so — can be difficult in practice and may create additional costs and legal risk.
We are particularly interested in evidence and examples on:
How often ‘hypothetical control’ is present in real financial sanctions cases;
The impact it has on compliance costs, legal risk and business decisions (including derisking);
Whether existing legal concepts and typologies of control are helpful in applying ownership and control regulations.
Read the full call for evidence and how to respond here.
Read more about the background and scope of the exercise in our blog here.
How are sanctioned goods licensed today in the UK? Why is that responsibility being transferred to OTSI? Were there any specific problems with the current situation? Provide sources for your analysis.
Gemini’s response:
As of today, April 11, 2026, the licensing of sanctioned goods in the UK is in the final stages of a major structural transition. While the Export Control Joint Unit (ECJU) still handles most “today,” a significant transfer of power to the Office of Trade Sanctions Implementation (OTSI) is scheduled for April 27, 2026.
Below is an analysis of the current landscape, the reasons for the transfer, and the systemic problems this change aims to solve.
1. How Sanctioned Goods are Licensed “Today” (April 11, 2026)
Currently, the responsibility is split between three primary bodies, often requiring businesses to apply for multiple licenses for a single transaction:
Export Control Joint Unit (ECJU): Historically the “heavy lifter,” the ECJU remains responsible for licensing strategic goods (military and dual-use items). For another two weeks, they also continue to process licenses for sanctioned goods (non-strategic items heading to sanctioned destinations like Russia).
Office of Trade Sanctions Implementation (OTSI): Launched in October 2024, OTSI currently handles the licensing of sanctioned services (e.g., professional, business, and legal services) and enforcement of trade sanctions for activities occurring outside the UK border.
Office of Financial Sanctions Implementation (OFSI): Handles the “financial” side (asset freezes and funds), as seen with the Maritime Mutual license discussed previously.
2. The Transfer to OTSI (Effective April 27, 2026)
From April 27, 2026, OTSI will take over the licensing of all sanctioned goods and associated ancillary servicesdestined for sanctioned countries.
What stays with ECJU: Strategic export controls (military/dual-use goods) will remain under the ECJU to ensure that national security expertise stays centralized.
The System: Even after the transfer, exporters will continue to use the SPIRE system for goods, while “standalone” services licenses will remain on the OTSI portal.
3. Why the Transfer? (Solving Specific Problems)
The UK Government’s May 2025 Cross-Government Review of Sanctions identified several “frictions” in the pre-2024 system that OTSI was created to fix:
A. The “Services Gap”
Before OTSI, the UK had robust enforcement for goods at the border (via HMRC), but enforcement for services (like accounting or consulting provided to sanctioned entities) was fragmented and lacked a dedicated civil enforcement body. OTSI provides a “civil” counterpart to OFSI, specifically for trade.
B. The Enforcement “Clarity” Problem
Historically, trade sanctions enforcement was primarily criminal, handled by HMRC. This created a high bar for prosecution. OTSI was granted the power to issue civil monetary penalties (up to £1 million or 50% of the breach value), allowing for more “proportionate and frequent” enforcement action against non-compliant businesses that didn’t meet the threshold for criminal intent.
C. Administrative Fragmentation
Businesses previously struggled with “license-stacking.” A single deal might require a financial license from OFSI, a goods license from ECJU, and a services license from the Department for Business and Trade (DBT). Moving sanctioned goods to OTSI concentrates trade-related expertise in one office, reducing the need for businesses to navigate multiple departments for the same sanctions regime.
D. The “Shadow Fleet” and Circumvention
Traditional export controls were designed for “shipment-to-destination” tracking. Modern sanctions evasion (like the Russian shadow fleet) often involves complex third-country brokering where goods never touch UK soil. HMRC’s powers are border-centric; OTSI was given broader jurisdiction over UK persons globally, allowing them to target circumvention that occurs entirely outside the UK.
Source List
OTSI Official Blog (April 9, 2026):“Expanding OTSI’s Licensing Remit” – Confirms the April 27 transition date.
GOV.UK Guidance (March 2026):“UK Government’s Strategic Approach to Sanctions Enforcement” – Details the civil penalty framework and the 2025 cross-government review findings.
OFSI Annual Review 2024-25: Provides data on the increase in license applications and the need for specialized “aftercare” services now being mirrored by OTSI.
Business and Trade Committee Report (February 2026): Correspondence from the Chair regarding the 185 investigations opened by OTSI in its first year, highlighting the “services sector” as the primary source of breaches.
Department for Business and Trade (DBT):“Trade Sanctions, Arms Embargoes, and Other Trade Restrictions”(Updated 2026).
Analysis of Source Support
Fully Supported: The dates of the transfer, the new civil penalty limits, and the split between strategic and sanctioned goods.
Inferred/Expert Analysis: The “Administrative Fragmentation” point is a common industry critique found in legal briefings (e.g., from Clifford Chance and Linklaters) and was a central theme of the 2025 review, though the government describes it more diplomatically as “improving the user experience.”
Any persons intending to use General Licence INT/2026/8893924 should consult the copy of the Licence for full details of the permissions and usage requirements.
Ten years ago, the Office of Financial Sanctions Implementation (OFSI) was established to ensure that the United Kingdom’s financial sanctions are clearly understood, effectively implemented and robustly enforced.
Over the past decade, financial sanctions have become an increasingly important tool in furthering the UK’s foreign policy, national security and economic aims. Financial sanctions now operate across a wider range of sectors, markets and jurisdictions than ever before. Their impact, and the demands placed on those responsible for implementing them, are continuing to grow.
Sanctions regimes and designations have expanded, and the scale of our sanctions’ implementation is reflected in recent figures. The OFSI Annual Review 2024-2025 saw £37 billion in assets be reported to OFSI as frozen across all sanction’s regimes.
From the outset, our role has been to ensure that financial sanctions work in practice, enabling the private sector to implement them effectively. That means ensuring measures are targeted and impactful, while minimising unintended consequences for legitimate activity and providing clarity for those required to comply with the rules.
We have strengthened the UK’s financial sanctions framework in several ways. Our engagement with industry has expanded through FAQs, guidance, threat assessments sector-specific advisories and outreach across a wide range of sectors.
Licensing remains a central part of the system, enabling legitimate activity to continue where appropriate while maintaining the integrity of sanctions restrictions. This includes a much-enhanced use of General Licences which has brought greater flexibility and efficiency for both public and private sectors.
Operational capability has also developed significantly, within OFSI as well as by working with law enforcement partners. Case prioritisation processes have been strengthened through greater use of data, helping identify risks and potential breaches earlier.
Since 2023, OFSI has successfully used its powers under the domestic counter-terrorism sanctions regime to designate and disrupt the activity of individuals and entities who pose risks to our national security.
International engagement has expanded, recognising that sanctions operate across borders and require close cooperation and alignment with partners to close loopholes. Legislative changes have strengthened reporting requirements and enforcement powers across the UK framework.
Enforcement has evolved as well. OFSI’s approach is increasingly targeted, intelligence-led and proactive, using a range of tools — including guidance, warning letters, public disclosure and civil monetary penalties — to promote compliance and deter breaches. Proportionate enforcement remains essential to maintaining confidence in the sanctions’ regime.
All this work supports business growth, deters circumvention, and maintains the credibility of the UK’s sanctions framework.
This anniversary is an opportunity for me to recognise the many people who have contributed to the development of the UK’s financial sanctions framework over the past decade. I would therefore like to take this opportunity to recognise the expertise and commitment of colleagues, the many people across government, industry, and international partners, and in particular the OFSI staff past and present, who have helped develop and support OFSI since its establishment.
As OFSI enters our second decade, our focus is firmly forward-looking and will be captured in a new three-year strategy to be published in the coming weeks. In April, we will convene with partners from across sectors at the OFSI10 Conference, where we will reflect back on our journey so far and look ahead to the future.
Ten years on, much has changed. But our mission remains the same: to ensure that the UK’s financial sanctions continue to be clearly understood, effectively implemented and robustly enforced.
OFSI General Licences INT/2022/2300292 and INT/2022/2009156 amended
On 31 March 2026, the General Licence INT/2022/2300292, Payments to Utility Companies for Gas and Electricity by UK Designated Persons who Own or Rent Properties in the UK was amended to to permit all forms of utility payment, including cash.
Any persons intending to use General Licence INT/2022/2300292 should consult the copy of the Licence for full details of the permissions and usage requirements.
On 31 March 2026, the General Licence INT/2022/2009156, Permitted Payments to UK Insurance Companies was amended to allow designated persons to make IPF repayments to UK intermediaries rather than insurers or brokers.
Any persons intending to use General Licence INT/2022/2009156 should consult the copy of the Licence for full details of the permissions and usage requirements.
Security Council ISIL (Da’esh) and Al-Qaida Sanctions Committee Adds One Entry to Its Sanctions List
On 26 March, the Security Council Committee pursuant to resolutions 1267 (1999), 1989 (2011) and 2253 (2015) concerning ISIL (Da’esh), Al-Qaida and associated individuals, groups, undertakings and entities approved the addition of the entry specified below to its ISIL (Da’esh) and Al-Qaida Sanctions List of individuals and entities subject to the assets freeze, travel ban and arms embargo set out in paragraph 1 of Security Council resolution 2734 (2024) and adopted under Chapter VII of the Charter of the United Nations.
A. Individuals
QDi.437 Name: 1: SAMI 2: JASIM 3: MUHAMMAD JAATA 4: AL-JABURI Name (original script): ﺳﺎﻣﻲ ﺟﺎﺳم ﻣﺣﻣد ﺟﻌﺎطﺔ اﻟﺟﺑوري Title: na Designation: na DOB: 1 Jul. 1974 POB: Iraq Good quality a.k.a.: a) Mustafa Adnan al-Aziz ﻣﺻطﻔﻰ ﻋدﻧﺎن اﻟﻌزﯾز (National Identification card no. 9080002892, issued by the Syrian Arab Republic, mother’s name Dahiyah al-Mulhim, DOB: 1 Jan. 1973, POB: Albu Kamal, Syria) b) Mustafa Adnan al-Azeez (Turkish Residency Card no. 4118 issued on 15 Jan. 2019) Low quality a.k.a.: a) Sami al-Ajuz(b) Hajji Hamid Nationality: Iraq Passport no: na National identification no: na Address: Iraq Listed on: 26 Mar. 2026 Other information: Assumed multiples roles within ISIL (Da’esh) listed as Al-Qaida in Iraq (QDe.115), including overseeing ISIL’s finances, material affairs and sources of revenue. He was also a member of the so-called Delegated Committee, which is the decision-making body of ISIL (Da’esh). He also participated in several terrorist operations against security forces while ISIL was controlling territory and was involved in the smuggling of oil derivates. Mother’s name: A’ishah Hasan. Gender:Male, Physical description: eye colour: black; hair colour: black; Photo available for inclusion in the INTERPOL-UN Security Council Special Notice. INTERPOL-UN Security Council Special Notice web link: https://www.interpol.int/en/How-we-work/Notices/View-UN-Notices-Individuals.
The ISIL (Da’esh) and Al-Qaida Sanctions List is updated regularly on the basis of relevant information provided by Member States and international and regional organizations. An updated List is accessible on the ISIL (Da’esh) and Al-Qaida Sanctions Committee’s website at the following URL: https://main.un.org/securitycouncil/en/sanctions/1267/aq_sanctions_list.
The United Nations Security Council Consolidated List is also updated following all changes made to the ISIL (Da’esh) and Al-Qaida Sanctions List. An updated version of the Consolidated List is accessible via the following URL: https://main.un.org/securitycouncil/en/content/un-sc-consolidated-list.
Security Council ISIL (Da’esh) and Al-Qaida Sanctions Committee Adds One Entry to Its Sanctions List
On 26 March 2026, the Security Council Committee pursuant to resolutions 1267 (1999), 1989 (2011) and 2253 (2015) concerning ISIL (Da’esh), Al-Qaida and associated individuals, groups, undertakings and entities approved the addition of the entry specified below to its ISIL (Da’esh) and Al-Qaida Sanctions List of individuals and entities subject to the assets freeze, travel ban and arms embargo set out in paragraph 1 of Security Council resolution 2734 (2024) and adopted under Chapter VII of the Charter of the United Nations.
A. Individuals
QDi.438Name: 1: ABD EL HAMID 2: SALIM 3: IBRAHIM BRUKAN 4: AL-KHATOUNI Name (original script): عبد الحميد سالم إبراهيم بروكان الخاتوني Title: na Designation: na DOB: 1 Sep. 1970 POB: Iraq Good quality a.k.a.: ABU OMAR AL SARRAF Low quality a.k.a.: na Nationality: Iraq Passport no: na National identification no: na Address: Iraq Listed on: 26 Mar. 2026 Other information: Served as a senior leader in ISIL (Da’esh) listed as Al-Qaida in Iraq (QDe.115) as its financial management officer. Mother’s name: Khadija Hattab Ismail. Gender: Male. INTERPOL-UN Security Council Special Notice web link: https://www.interpol.int/en/How-we-work/Notices/View-UN-Notices-Individuals.
The ISIL (Da’esh) and Al-Qaida Sanctions List is updated regularly on the basis of relevant information provided by Member States and international and regional organizations. An updated List is accessible on the ISIL (Da’esh) and Al-Qaida Sanctions Committee’s website at the following URL: https://main.un.org/securitycouncil/en/sanctions/1267/aq_sanctions_list.
The United Nations Security Council Consolidated List is also updated following all changes made to the ISIL (Da’esh) and Al-Qaida Sanctions List. An updated version of the Consolidated List is accessible via the following URL: https://main.un.org/securitycouncil/en/content/un-sc-consolidated-list.
UK email notification, which includes links to the FCDO’s UK Sanctions List designation listings:
Today, Friday 27 March, the UK Government has designated the following 2 individuals under the Isil (Da’esh) and Al-Qaida Sanctions Regime. This reflects the decision to designate these individuals made by the UN Security Council Sanctions Committee pursuant to Resolutions 1267 (1999), 1989 (2011) & 2253 (2015) on 26 March.
Any persons intending to use General Licence INT/2023/2824812 should consult the copy of the Licence for full details of the permissions and usage requirements.
