OFSI General Licence INT/2025/8031092 amended
On 19 June 2026, the Continuation of Business of Lukoil International Entities General Licence (INT/2025/8031092) was amended to remove the restriction set out in paragraph 4.2.
Any persons intending to use General Licence INT/2025/8031092 should consult the copy of the Licence for full details of the permissions and usage requirements.
The Publication Notice:
and the General Licence:
Claude’s Summary:
At a Glance
- Subject: Sabre Global Technologies Limited (SGTL)
- Sector: Travel technology; operates a Global Distribution System (GDS) giving travel-industry entities access to travel-supplier content
- Authority: OFSI (HM Treasury), under section 146 of the Policing and Crime Act 2017
- Date of Penalty: 26 May 2026
- Penalty Amount: £1,000,920.59 (reduced from a baseline of £1,251,150.73 by a 20% discount)
- Sanctions Regime: Russia (Sanctions) (EU Exit) Regulations 2019
- Provisions Breached:
- Regulation 13 — making funds available for the benefit of a designated person
- Regulation 14 — making economic resources available to a designated person
- Regulation 19 — circumventing prohibitions
- Designated Person / Nexus: JSC Ural Airlines (Ural Airlines), designated under the Russia Regulations on 19 May 2022; unique ID RUS 1446
- Guidance Applied: November 2024 Financial Sanctions Enforcement and Monetary Penalties Guidance (the version in force at the decision to issue notice); resolved by settlement under the transitional arrangements of OFSI’s new settlement policy introduced February 2026
- Resolution: Settlement under transitional arrangements — the third penalty resolved this way, and OFSI’s first penalty for a circumvention offence
What Happened
SGTL had supplied services to Ural Airlines since 2007. The contract, signed on 14 September 2007, gave the airline access to SGTL’s GDS and was extended several times — most recently updated on 1 December 2021, with a later amendment on 1 September 2022.
On 19 May 2022, Ural Airlines was designated under the Russia Regulations and added to the UK consolidated list. SGTL’s legal representatives told it the same day. Access did not stop. The airline kept its GDS connection until 6 December 2022 — roughly seven months — and SGTL chose simply not to renew the contract rather than cut off access on designation.
The money moved in parallel. In April, May, and June 2022, SGTL invoiced Ural Airlines and instructed that funds be paid into its account, totalling $906,576.30 (£744,305.13). Three related payments followed between June and September 2022, and SGTL’s UK bank froze each of them.
The warnings were not subtle. SGTL’s UK bank held a 3 June payment on 6 June, declined to process it on 27 June, and held the 1 July payment on 5 July; on 21 September, SGTL’s US bank flagged the September payment for compliance review. Through July and August 2022, rather than stopping, SGTL looked for another way to be paid — engaging its US bank to test whether funds from Ural Airlines could land in a US account, and expressly citing the sanctions problems on its UK account. Internal emails in August and October 2022 show the plan: if a test payment cleared, SGTL expected Ural Airlines to settle the full outstanding GDS fees by that route. On 21 September 2022, Ural Airlines sent a $200 (£176.48) test payment to the US account. OFSI considered the object or effect of that payment to be circumvention of the Russia Regulations.
OFSI identified why the controls failed. The senior responsible officer misunderstood which Sabre-group entity held the Ural Airlines contract and, while transitioning out of the role, did not escalate what he knew. A wider restructuring left SGTL for a time without a permanent Chief Legal Officer or Chief Compliance Officer, and the legal team short-staffed. The firm’s sanctions documentation leaned on general procedures and US requirements rather than the UK regime — and its third-party screening software never automatically flagged the designation to compliance.
SGTL made a voluntary disclosure to OFSI on 31 October 2022, covering the three frozen payments, and cooperated with the investigation that followed. OFSI issued a Notice of Intention to impose a penalty on 16 January 2026; SGTL submitted formal representations on 24 February 2026; the parties agreed to enter settlement discussions under transitional arrangements on 16 March 2026; and on 26 May 2026 settlement was agreed and the penalty imposed. As a condition of settlement, SGTL agreed to pay the penalty as imposed and to waive its rights to ministerial review and to appeal OFSI’s decision to the Upper Tribunal on matters within the settlement’s scope.
The Breaches
- Regulation 13 — making funds available for the benefit of a designated person: SGTL’s contract created a debt obligation. By invoicing Ural Airlines and instructing payment into its account, SGTL made funds available to its bank for the airline’s benefit. Under reg. 13(4)(a), funds are made available “for the benefit of” a designated person where that person thereby obtains or is able to obtain a significant financial benefit — and OFSI assessed that Ural Airlines did, because the payments discharged its financial obligations to SGTL.
- Regulation 14 — making economic resources available to a designated person: SGTL provided an economic resource directly to Ural Airlines by allowing continued GDS access between 19 May and 6 December 2022.
- Regulation 19 — circumventing prohibitions: During July–August 2022, SGTL explored alternative routes to receive funds from Ural Airlines via its US bank, expressly referencing the prior UK-account sanctions problems, and arranged a $200 (£176.48) test payment on 21 September 2022 with a view to routing the full outstanding amount the same way. OFSI assessed the object or effect of this as circumvention.
Valuation of the Breach
- Total Assessed Value: $3,222,379.89 (£2,634,001.54) — the combined value of funds and economic resources in breach of regs. 13, 14, and 19, calculated to avoid double-counting amounts already paid by Ural Airlines.
- Regulation 14 — economic resource: $2,576,550.57 (£2,107,876.02), OFSI’s assessment of the value of the economic resource provided between 19 May and 6 December 2022 (includes VAT).
- General Licence deduction: less $50 (£40.91) for booking fees paid by UK persons, in line with OFSI’s Russian Travel General Licence (INT/2022/1839676).
- Regulation 13 — frozen June 2022 payment: $312,129.65 (£248,143.07), for services provided in April 2022, separate from the 19 May–6 December period (includes VAT).
- Regulation 13 — pro rata July 2022 payment: $333,549.67 (£277,846.87), for services provided 1–18 May 2022 (includes VAT).
- Regulation 19 — test payment: $200 (£176.48), the 21 September 2022 test payment.
OFSI noted that the portion of the July payment for services 19–31 May 2022 and the September 2022 payment were not separately included in the reg. 13 value, being treated as captured within the economic-resource valuation.
OFSI’s Case Assessment
- Aggravating Factors:
- (case factor A) SGTL actively explored alternative means to receive payment, including requesting a test payment to a non-UK account and planning to route future settlements through it — circumvention of the Russia Regulations.
- (case factor B) The value of the breaches was high.
- (case factor C) Ural Airlines was designated for supporting the Russian government in the strategically significant transport sector; by enabling GDS access, SGTL undermined the regime’s objectives. That the payments ran from Ural Airlines to SGTL was not mitigating to harm, as they were for continued provision of services.
- (other relevant factors under severity) Sanctions against Russia are a strategic priority for the UK and its foreign policy.
- (case factor D) SGTL had reasonable cause to suspect its actions could breach UK sanctions; seeking alternative payment routes and continuing the relationship after designation amounted to circumvention.
- (case factor E) During the breach period SGTL lacked competent senior oversight of sanctions and could not properly assess or mitigate its exposure or understand its responsibilities. Although post-breach remediation was positive, knowledge and systems during the breach period were assessed overall as aggravating.
- (case factor G) SGTL did not seek advice or consider applying for a licence to permit receipt of payments or continued service despite multiple red flags.
- (case factor I) The provision of an economic resource ran over seven months (19 May–6 December 2022).
- Mitigating Factors:
- (case factor K) Although the initial report was incomplete, SGTL provided significant detail on the underlying causes throughout, conducted internal investigations, gave full and timely responses to voluntary questions, and demonstrated full co-operation with OFSI.
- Neutral Factors:
- (case factor J) SGTL’s disclosure was voluntary and unprompted but contained limited information; SGTL did not proactively submit further information before OFSI’s formal request in June 2023 and continued providing services after the initial report, yet cooperated fully and promptly with each subsequent request. On balance, neither aggravating nor mitigating.
- Overall Assessment: “Most serious” (as opposed to “serious”). OFSI cited particularly poor conduct through circumvention, negligent conduct including continued provision of services for months after identifying potential breaches, and the direct undermining of the regime by providing an economic resource directly to a designated person. OFSI viewed SGTL’s remediation as constructive but largely addressing deficiencies that should have been in place at the time.
How the Penalty Was Calculated
- Total Breach Value: £2,634,001.54
- Statutory Maximum: £1,317,000.77 (the greater of £1m or 50% of the breach value, under the framework applied)
- Baseline Penalty: £1,251,150.73 (OFSI’s assessed reasonable and proportionate baseline)
- Discount Applied:
- Voluntary disclosure and settlement under transitional arrangements: 20%
- Final Penalty: £1,000,920.59
OFSI applied the November 2024 Enforcement Guidance, under which it may reduce a “most serious” case by up to 30% for voluntary disclosure; here it applied a 20% discount.
Compliance Lessons
- Do not engineer alternative payment routes to evade sanctions: Firms must not test, reroute, restructure, or otherwise manipulate payment pathways — including staging payments through third countries — to avoid, evade, or defeat UK sanctions. Such conduct may itself be circumvention and will be treated as aggravating.
- Recognise intangible and digital services as “economic resources”: Economic resources are assets of every kind that are not funds but can be used to obtain funds, goods, or services. Software, data services, and digital tools are not assumed outside scope; a service that lets a designated person generate revenue, maintain operations, or gain an economic advantage may be an economic resource. Firms should assess all products and services and seek specialist legal advice where uncertain.
- Maintain UK-tailored policies, oversight, and screening: Sanctions policies for UK operations must be tailored to the UK regime, supported by competent senior oversight and clear accountability. Firms should test that screening systems work as intended, maintain robust escalation, and act on red flags such as blocked payments or notifications of sanctions concerns from financial institutions.
- Report breaches promptly, comprehensively, and in detail: Suspected breaches should be reported to OFSI as soon as reasonably practicable. Delay and incomplete submissions undermine mitigation. Where full disclosure is not yet possible, firms should make an early partial disclosure, provide a timeline for the full account, and follow up as indicated.
Supplemental Information: Per the HM Treasury press release, this is the UK’s largest penalty for a breach of Russian financial sanctions since the 2022 invasion of Ukraine, and OFSI’s first penalty issued specifically for a circumvention offence. It is the third case resolved under the transitional arrangements of OFSI’s new settlement policy, introduced in February 2026. Ural Airlines — the designated nexus — is a Russian carrier sanctioned as part of the UK’s targeting of the Russian transport sector; the Russian Travel General Licence (INT/2022/1839676) referenced in the valuation permits certain UK-person travel-related payments to specified Russian carriers, which is why a small booking-fee amount was deducted from the breach value. More broadly, OFSI’s enforcement framework changed materially on 9 February 2026: for cases assessed under that newer framework, the voluntary-disclosure discount is capped at 30% and gated on a separate co-operation limb, settlement carries a discount of up to 20%, seriousness is assessed on a four-level matrix, and the statutory maximum is being raised toward the greater of £2m or 100% of the breach value. Those mechanics did not drive the calculation here, which OFSI made under the November 2024 guidance, but they are the standard the next comparable case will be measured against.
Sources
- November 2024 Financial Sanctions Enforcement and Monetary Penalties Guidance, OFSI / HM Treasury — https://www.gov.uk/government/publications/financial-sanctions-enforcement-and-monetary-penalties-guidance/financial-sanctions-enforcement-and-monetary-penalties-guidance
- “New and updated enforcement framework – a message from Giles Thomson, Director of OFSI” (9 Feb 2026 framework context) — https://ofsi.blog.gov.uk/2026/01/29/new-and-updated-enforcement-framework-a-message-from-giles-thomson-director-of-ofsi/
Validation Note
Checks performed against the SGTL penalty notice and the HM Treasury press release.
- Source-tracing: Every labelled value and narrative claim traces to the notice or the press release; supplemental context (largest-penalty / first-circumvention framing, settlement-policy context, General Licence purpose, Feb 2026 framework mechanics) is confined to the Supplemental block and Sources.
- No paragraph coupling: Extraction was by meaning; the SGTL notice’s own paragraph numbering is not relied on anywhere in the output.
- Figures: The breach-value components reconcile to the stated total once OFSI’s stated avoidance of double-counting is applied (reg. 14 economic resource £2,107,876.02 less £40.91 GL deduction, plus reg. 13 components £248,143.07 and £277,846.87, plus the £176.48 test payment ≈ £2,634,001.53, matching the stated £2,634,001.54 to within rounding). Statutory maximum £1,317,000.77 = 50% of the breach value, consistent with the framework applied. Baseline £1,251,150.73 less 20% = £1,000,920.58, matching the imposed £1,000,920.59 to within one penny of rounding. No figures were altered.
- Guidance regime: The notice states it applied the November 2024 Enforcement Guidance (the version in force at the decision date), under which a “most serious” case may receive up to a 30% voluntary-disclosure reduction; the 20% discount applied is consistent. The newer 9 February 2026 framework is noted as context only and was not used to recompute anything.
- Provisions: Regs. 13, 14, and 19 are mapped to the descriptors the notice itself uses.
- Subject/nexus: Facts about SGTL are kept distinct from those about Ural Airlines; Ural’s designation date and unique ID (RUS 1446) are drawn from the notice.
- Terminology: “Breach” used throughout; “violation” (the OFAC term) does not appear.
- One discrepancy flagged: The notice gives the Notice of Intention as 16 January 2026 and representations as 24 February 2026, while also stating the settlement-enabling framework took effect 9 February 2026 — i.e. the framework post-dates the Notice of Intention, which is why the case proceeded under transitional arrangements rather than the new settlement scheme proper. This is reproduced as stated, not corrected.
And the actual text of the penalty notice:
Mr. Sanctions’ Note: I had Claude create a master prompt for OFSI penalty notices with the OFAC format as a guide. Since the actual notices differ in vocabulary, format and style, it is somewhat different – although I had Claude make the sentence structures more OFAC-like (fewer longer sentences). What do you think?
Today, Tuesday 16 June 2026, the UK Government has designated the following 11 individuals and 32 entities, and specified the following 27 ships, under the Russia Sanctions Regime.
Designated Individuals:
Name: Unique ID: Alexander Petrovich VORONKOV RUS3639 Ruslan Petrovich KOSHKIN RUS3649 Aleksandr Filippovich VOTCHENKO RUS3650 Nikolay Nikolayevich SAZHIN RUS3651 Sergey Nikolayevich MAZURIK RUS3652 Aleksandr Vasilyevich MATROSOV RUS3653 Roman Viktorovich GAIVORONSKIY RUS3654 Dmitriy Yegorovich ZUBKOV RUS3655 Stanislav Sergeyevich POPOV RUS3656 Konstantin Aleksandrovich STRAFILOV RUS3657 Maksim Yuryevich MAMONTOV RUS3658 Designated Entities:
Name: Unique ID: JOINT-STOCK COMMERCIAL BANK “EVROFINANCE MOSNARBANK” (JOINT-STOCK COMPANY) RUS3620 JOINT STOCK COMPANY “YANDEX BANK” RUS3621 LIMITED LIABILITY COMPANY “WILDBERRIES BANK” RUS3622 JOINT-STOCK COMPANY COMMERCIAL BANK “VYATICH” RUS3623 LLC SCIENTIFIC AND PRODUCTION ENTERPRISE SPETSENERGOMEKHANIKA RUS3624 JSC RUSHOL RUS3625 LLC TECHNOPARITET RUS3626 LLC NEPTUNE CO LTD RUS3627 LLC MAGNUS LINK RUS3628 JSC INTERCONSUL RUS3629 SHTRAL TECHNOLOGY CO LTD RUS3630 SHTRAL MAKINE ITHALAT IHRACAT SANAYI VE TICARET LIMITED RUS3631 IC-ORIENTIR RUS3632 LLC TPK PEGAS RUS3633 SHENZHEN HUAXIN ANTENNA TECHNOLOGY CO LTD RUS3634 COMNAV TECHNOLOGY LTD RUS3635 JOINT STOCK COMPANY MARINE BRIDGE AND NAVIGATION SYSTEMS RUS3636 P.K.T. MUNGMEE CO., LTD RUS3637 LIMITED LIABILITY COMPANY TEKHNOPOL RUS3638 THAI TRADE ASSOCIATION CO., LTD RUS3640 AEROGLOBAL CO., LTD RUS3641 BRUKIDA LIMITED RUS3642 LLC SMITH RUS3643 OOO DILMAS RUS3644 KOMPOZIT 21 LLC RUS3645 OOO KORD-BUNKER RUS3646 JOINT DEVELOPMENT BANK RUS3647 “A71” LIMITED LIABILITY COMPANY RUS3648 “A7-AGENT” LIMITED LIABILITY COMPANY RUS3659 PILOT FINANCE LIMITED RUS3660 JSC BALANCE INSURANCE RUS3688 JSC ROSGOSSTRAKH RUS3689 Specified Ships:
Name: Unique ID: IMO 9296377 (“MARJORIE”) RUS3661 IMO 9305556 (“MARVEN”) RUS3662 IMO 9390587 (“ONEIROI”) RUS3663 IMO 9333785 (“SEADAR”) RUS3664 IMO 9291262 (“SILVAR”) RUS3665 IMO 9290397 (“STORMBRINGER”) RUS3666 IMO 9417464 (“TANI”) RUS3667 IMO 9298492 (“TOA PAYOH”) RUS3668 IMO 9290385 (“ELBUS”) RUS3669 IMO 9270555 (“INTEGRITY RACER”) RUS3670 IMO 9380570 (“KURDOS III”) RUS3671 IMO 9249128 (“SAKHALIN”) RUS3672 IMO 9408542 (“LING HONG”) RUS3673 IMO 9294264 (“ORION”) RUS3674 IMO 9326689 (“MERKURIY”) RUS3675 IMO 9300817 (“KOSMOS”) RUS3676 IMO 9317315 (“LUCH”) RUS3677 IMO 9328170 (“AETHER”) RUS3678 IMO 9337418 (“ATMOS”) RUS3679 IMO 9439383 (“BHILVA”) RUS3680 IMO 9297541 (“DOVE”) RUS3681 IMO 9198082 (“GLOBAL STAR”) RUS3682 IMO 9408554 (“HE BO”) RUS3683 IMO 9413004 (“HORAE”) RUS3684 IMO 9282041 (“KAVIZ”) RUS3685 IMO 9274082 (“TM HAI HA 568”) RUS3686 IMO 9379301 (“VERSA”) RUS3687
The Sanctions Notice:
and a press release from the PM himself, FCDO, and Secretary of State Yvette Cooper:
UK announces major new sanctions package choking off Russia’s war effort across multiple fronts.
From: Foreign, Commonwealth & Development Office, The Rt Hon Yvette Cooper MP and The Rt Hon Sir Keir Starmer KCB KC MP
Published16 June 2026
The UK has unleashed a major new sanctions package choking off Russia’s war effort across multiple fronts.
New action directly targets Russia’s illicit shadow fleet and finance networks used to circumvent Western sanctions and support military procurement.
Today’s sanctions further crack down on Russia’s decrepit and ageing shadow fleet, targeting more than 20 oil tankers with new and enhanced powers introduced last month. The UK is also tightening the net around those who are suspected of enabling Putin’s illicit oil trade, further sanctioning ship insurers and other shipping services.
The UK is the first G7 country to sanction several Liquefied Natural Gas (LNG) vessels recently acquired by Russia at great expense to service Russia’s sanctioned Arctic LNG 2 project, responsible for exporting millions of tonnes of LNG, in an attempt to source dirty revenue for the Kremlin.
These sanctions target the vessels, the money and the actors propping up Russia’s war economy, and in turn, threatening European security.
Working with our G7 allies, we will continue to increase the pressure in Putin and his circle of collaborators until Russia’s war machine is brought to a halt and peace returns to our continent.
As the Kremlin resorts to ever more shady tactics to sustain its war, from its ageing shadow fleet to covert finance networks, the UK remains one step ahead in shutting them down.
These sanctions strike at the heart of these murky efforts, to starve Putin’s war machine and defend Britain’s security.
Shoulder to shoulder with our G7 partners, the UK will stand with Ukraine for as long as it takes.
Those who are suspected of enabling the sale of tankers to Russia’s shadow fleet will be exposed and face action. UK sanctions are greatly limiting Russia’s ability to trade oil – in 2025 the Arctic LNG-2 terminal only exported 1.3 million tons of LNG despite having capacity to export over 13.5 million tons a year.
To date, the UK has now sanctioned more than 600 shadow fleet and Russian LNG vessels.
New measures also expose and target a Russian military intelligence (GRU) network centred around GRU front company LLC Neptune Co Ltd (‘Neptune’).
Neptune is involved in covertly procuring western technology for Russia’s military.
Today’s actions target three companies and 10 GRU officers suspected of acquiring military technology that Russia desperately needs to sustain its military aggression in Ukraine.
Elsewhere, sanctions also hit third country suppliers of critical military equipment to Russia in China, Thailand and Türkiye. Several organisations helping Russia illegally move money, bypassing western sanctions, are also targeted including one entity in Nigeria supporting the illicit finance network A7’s sanctions evasions scheme.
Gathering in Évian-les-Bains, G7 Leaders will discuss their joint determination to tackle the single largest threat to global security – Russia’s illegal war in Ukraine.
As the UK increases pressure on Russia’s war economy, today’s action demonstrates an unshakeable determination to defend security in Ukraine, Europe and at home.
 |
OFSI General Licence INT/2026/9559192 issued
General Licence INT/2026/9559192 has been issued. The General Licence permits defined persons to take any necessary steps to enable and enact the Interdiction.
Any persons intending to use the General Licence should consult that Licence for full details of the definitions, permissions and usage requirements.
Here’s the GL’s Publication Notice:
and the General Licence:
New FAQs added – Transneft ports, payments and insurance
OFSI has published new FAQs (188-195) clarifying how UK financial sanctions apply in relation to Transneft and associated activity. These FAQs provide additional guidance to industry on how relevant prohibitions operate in practice, including when a licence may be required and how firms should approach compliance risks.
The FAQs respond to stakeholder queries and aim
sto support a consistent understanding of the regime, helping to reduce the risk of circumvention. We encourage insurers, financial institutions and maritime operators to review the guidance and ensure internal processes reflect these considerations.
Here they are:
PJSC Transneft
188. Does insuring a vessel calling at a PJSC Transneft owned or controlled port automatically engage UK sanctions?
No.
UK insurers providing insurance or reinsurance cover for vessels simply calling at PJSC Transneft-owned or controlled ports, in itself, is unlikely to engage UK financial sanctions.
The fact that a UK insured vessel calls at a PJSC Transneft owned or controlled port does not, in itself, automatically engage UK financial sanctions. Although UK financial sanctions do not determine whether a vessel may call at a particular port, UK financial sanctions, however, may still apply to any financial activities connected with such voyages.
Questions relating to port access, shipping routes, or trade restrictions fall outside the scope of UK financial sanctions and are governed by other regulatory frameworks.
For guidance on assessing insurance claims, see FAQs 189-190.
Added on: 11 Jun 2026
189. What are some of the key considerations when assessing insurance claims and payouts relating to PJSC Transneft owned or controlled ports?
Depending on the specific facts of the case, the key considerations are whether a payment under an insurance policy would engage the asset freeze prohibitions, for example regulations 12 and 13 of the Russia Regulations- making funds available to, or for the benefit of, designated persons, including PJSC Transneft.
If so, a licence from OFSI would be required before any such payment can be made.
Added on: 11 Jun 2026
190. Can UK insurers pay claims that do not involve PJSC Transneft or PJSC Transneft owned or controlled ports?
Whether or not such claims can be paid without an OFSI licence will depend on the circumstances and facts of the case.
For example, although a payment may not result in a direct payment to a PJSC Transneft owned or controlled port/entity, firms must assess whether other UK asset freeze prohibitions are engaged, for example regulation 13 of the Russia Regulations- making funds available for the benefit of a designated entity, including PJSC Transneft.
Firms must make their own assessment on whether any indirect benefit arises to a designated person or whether any of the other asset freeze prohibitions are engaged.
Added on: 11 Jun 2026
191. Does compliance with EU or other sanctions regimes ensure compliance with UK sanctions?
No.
Compliance with EU or other sanctions regimes as it relates to PJSC Transneft should not be taken as evidence of compliance with UK financial sanctions. The UK maintains an independent sanctions framework, and firms must ensure full adherence to UK specific requirements.
Added on: 11 Jun 2026
192. Do payments made in connection with calling at a PJSC Transneft-owned or controlled port engage UK financial sanctions?
Potentially.
Primarily, there will have to be a UK nexus in relation to the payment(s). Once this has been established, payments such as port fees and terminal charges, amongst others, may engage UK financial sanctions if for example funds are made available to, or for the benefit of, designated persons, including PJSC Transneft (regulations 12 and 13 of the Russia Regulations).
In such cases, the asset freeze prohibitions are likely to apply, and a licence from OFSI may be required. It is for firms (including UK shipowners, charterers or ship managers for example) to assess whether UK financial sanctions are engaged in relation to such payments.
Added on: 11 Jun 2026
193. Can UK financial institutions support transactions linked to voyages involving PJSC Transneft infrastructure?
UK financial institutions (such as banks or other financial firms) must assess transactions on a case-by-case basis.
Where a transaction would result in funds or economic resources being made available to, or for the benefit of PJSC Transneft, the asset freeze prohibitions are likely to apply (Regulations 12 and 13 of the Russia Regulations).
Financial institutions should ensure they conduct appropriate due diligence and consider whether an OFSI licence is required before processing any such transaction.
Added on: 11 Jun 2026
194. Does the involvement of PJSC Transneft infrastructure (e.g. oil pipelines or storage facilities) automatically engage UK financial sanctions (where a UK nexus exists)?
No.
The mere involvement of PJSC Transneft infrastructure in a supply chain does not, by itself, automatically engage UK financial sanctions. However, firms must conduct their own assessment and apply for an OFSI licence should one be required, for example, where involvement of PJSC Transneft infrastructure will result in funds being made available to PJSC Transneft (Regulation 12 of the Russia Regulations).
Added on: 11 Jun 2026
195. Do UK financial sanctions apply to goods (e.g. oil) transported via Transneft infrastructure (e.g. pipelines)?
Not automatically.
UK financial sanctions are unlikely to be engaged solely because goods have been transported via infrastructure owned or controlled by a designated person (such as PJSC Transneft).
However, the asset freeze prohibitions for example may be engaged where activities involving those goods (including payments for transport, storage or port services) result in funds being made available to, or for the benefit of, designated persons, including PJSC Transneft (regulations 12 and 13 of the Russia Regulations). Firms must conduct their own assessment on whether UK financial sanctions are engaged and apply for an OFSI licence should one be required.
Added on: 11 Jun 2026
Mr. Sanctions’ editorial note: It would be really, really nice if OFSI’s links went directly to the thing they reference. In this case, the link takes you to the start of the Russia FAQ section, even though there is a special heading for these Transneft FAQs. And when there is a sanctions update, that link takes you to a page where you then have to click again to get to the actual PDF. Yeah, it’s a comparatively small thing, but a blogger can dream, can’t he?
Today, Tuesday 09 June, the UK Government has varied the following 3 individuals and 2 entities under the Russia (Sanctions) (EU Exit) Regulations 2019.
Individuals varied:
Entities varied:
The sanctions notice:
Today, Tuesday 9 June, the UK Government has designated the following individual and 6 entities under the Global Human Rights Sanctions Regime.
Individuals designated:
Name: Unique ID: Itamar Yehuda LEVY GHR0191 Entities designated:
The sanctions notice:
and the FCDO press release (unusual for these releases):
Press release
Foreign Secretary Yvette Cooper announces co-ordinated sanctions with international partners targeting individuals and entities involved in financing and enabling settler violence in the occupied West Bank. From:Foreign, Commonwealth & Development Office, Department for Business and Trade and The Rt Hon Yvette Cooper MPPublished9 June 2026
In a statement to Parliament today, the Foreign Secretary will announce that the UK, alongside partners (Canada, France and Norway) is imposing new sanctions. The UK will impose sanctions on 6 entities and one individual involved in financing, enabling and carrying out settler violence in the occupied West Bank. Australia and New Zealand published co-ordinated sanctions last week.
Australia, Canada, France, Norway, and the United Kingdom have all taken the historic decision to recognise the State of Palestine, reflecting the rights of the Palestinian people and as part of our common efforts to protect the viability of the two-state solution. Today, they are acting together again in support of the same objectives.
Those designated will face asset freezes and, where appropriate, travel bans and Director Disqualifications. These sanctions will disrupt the flows of finance that have allowed extremist settler groups to act with impunity in the West Bank and demonstrate the UK’s commitment to a two-state solution.
The UK position remains clear: settlements are illegal under international law, they undermine international efforts to secure a just, lasting peace in the Middle East, and they risk doing permanent damage to the prospects of a secure and viable Palestinian state being able to live in peace alongside a secure Israel.
For the first time, the Foreign Secretary has also announced that the UK’s official guidance will explicitly advise businesses against economic and financial activity in illegal settlements. The UK continues to support trade with Israel within 1967 lines, but states that there should be no economic involvement in illegal settlements.
Foreign Secretary Yvette Cooper is expected to say:
Today we are acting with our international partners to sanction those who support and sponsor violence against Palestinian communities in the West Bank.
Settler expansion and violence is illegal and a fundamental threat to the viability of a two-state solution, and to long-term peace and security for Palestinians and Israelis.
These measures show the UK is leading with our partners to target those who are fuelling this violence.
These steps come against a backdrop of continued illegal settlement expansion including the E1 project, which further undermines the viability of a two-state solution, and record levels of settler violence designed deliberately to destroy Palestinian homes and livelihoods in the West Bank.
The UK continues to urge the Government of Israel to end settlement expansion, clamp down on settler violence, prosecute those responsible, and lift ongoing restrictions on the functioning of the Palestinian economy. The UK will not hesitate to take further action if the situation does not improve.
Today’s measures form part of a wider UK effort to advance peace and security in Israel and Palestine. This includes action to support implementation of the 20 Point Plan for Gaza and protect and strengthen a viable Palestinian state.
The Foreign Secretary is also expected to announce today that the UK will provide an additional £1 million for humanitarian mine action in Gaza in addition to the £4 million already contributed. She will call on the Government of Israel to open all crossings and remove arbitrary restrictions on the delivery of humanitarian aid and equipment to ensure that UK aid can reach all those who desperately need it.
She will also announce that she will travel to Paris this week in advance of the Peace Building Conference, which is bringing together Israeli and Palestinian civil society, and international partners dedicated to advancing the two-state solution.
In addition, the Foreign Secretary will confirm at least £10 million in financial and technical assistance to the Palestinian Authority in 2026, including support to navigate the fiscal crisis and sustain frontline services such as healthcare.
Sanctioned individuals and entities include:
The overseas business risk service provides information on various risks in overseas markets. We intend these pages to support and guide businesses. You should view them alongside other sources of information. The UK government does not advise on, or undertake due diligence for individual companies.
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Mandatory corporate action FAQ added
Today, OFSI has published FAQ 187 on how mandatory corporate actions (MCAs) engage the Russia and Belarus Regulations, providing clarity for those trading transferable securities and money market instruments.
The FAQ explains that new instruments, created through an MCA will not automatically engage Regulation 16 of the Russia Regulations or Regulation 15A of the Belarus Regulations. Whether these provisions apply will depend on the specific facts, and the FAQ includes a worked example illustrating how this assessment may be made.
This guidance supports firms to continue trading whilst remaining compliant with UK sanctions.
Frequently Asked Question 187:
187. For the purposes of regulation 16 of the Russia Regulations and regulation 15A of the Belarus Regulations, how should the “date of issue” of a transferable security or money market instrument be determined, including where instruments or securities issued pursuant to a mandatory corporate action (MCA) relate to securities or instruments issued prior to the dates referred to in regulations 16 and 15A?
These regulations prohibit dealing with transferrable securities and money market instruments issued by certain persons on or after certain specified dates. Dealing with transferrable securities and money market instruments that were issued before the specified dates is not prohibited, provided the activity does not otherwise breach the Russia Regulations or the Belarus Regulations (e.g. by making funds available to a designated person).
In some cases, a new transferable security or money market instrument is created in respect of an instrument or security issued prior to the specified dates referred to above (including in the context of an MCA) which could then potentially be caught by the relevant regulations. Determining whether this is the case is fact-dependent and will be considered by OFSI on a case-by-case basis (but determinations will only be made if relevant to specific OFSI casework). In that consideration, OFSI will place significant weight on whether an issuance (including as part of an MCA) results in finance being raised for the issuer.
For example, regulation 16 or regulation 15A may not apply if:
- Shares subject to regulation 16 (or regulation 15A) originally issued prior to the relevant date in regulation 16 (or regulation 15A) become subject to a mandatory stock split after that date;
- that stock split does not raise new finance for the company undertaking it; and;
- there is no material change to the rights and/or value of the shares.
Added on: 8 Jun 2026
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Today, Thursday 4th June, the UK Government has revoked one entity and amended one individual, both sanctioned under the Russia Sanctions Regime.
Revoked Entity:
Name: Unique ID: Limited Liability Company responsibility of “RBRU Specialized Depository” RUS2682 Amended Individual:
Name: Unique ID: Liran COHEN RUS3607
and here’s the sanctions notice:
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Today, Tuesday 2nd June, the UK Government has varied the designation of the following individual under the Global Anti-Corruption Sanctions Regime.
Individuals Varied:
Name: Unique ID: Sarju RAIKUNDALIA GAC0051
The Sanctions Notice:
