Mr. Sanctions

Category: OFSI (UK)

  • May 14, 2026: OFSI tweaks its Russian, Afghanistan and Iran designations

    UK Gov logo, 50% resolution.png

    Today, Thursday 14 May, the UK Government has revoked 1 specification, varied 1 designation, and made 3 amendments to designations imposed under the Russia Sanctions Regime.

    Revoked Specification:

    Name:IMO Number:Unique ID:
    MILLEROVOIMO 9035541RUS2605

    Varied Individual:

    Name:Unique ID:
    Yulia GURYEVA-MOTLOKHOVRUS2066

    Amended Individuals:

    Name:Unique ID:
    Pavel Valerevich NIKITINRUS3515
    Dmitriy Evgenievich SHEVCHENKORUS3519
    Timofey Vladimirovich VASILIEVRUS3573

    Furthermore, the UK Government has amended 4 designations made under the Iran Sanctions Regime.

    Amended Individuals:

    Name:Unique ID:
    Namiq SALIFOVIRN0269
    Nihat Abdul Kadir ASANIRN0270
    Reza HAMIDIRAVARIIRN0271
    Farhad ZARRINGHALAMIRN0274

    Lastly, the UK Government has amended 1 designation made under the Afghanistan Sanctions Regime.

    Amended Individual:

    Name:UN ID:Unique ID:
    Nooruddin Turabi Muhammad QASIMTAi.058AFG0046

    Heres’s the sanctions notices – Russia:

    Sanctions_Notice__Russia__14_May_2026Download

    Iran:

    Sanctions_Notice__Iran__14_May_2026Download

    and Afghanistan:

    Sanctions_Notice__Afghanistan__14_May_2026Download

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  • Burning Question: What’s in OFSI’s Financial sanctions guidance for High Value Dealers & Art Market Participants?

    Here is the complete summary:

    What Is This Document?

    This guidance is produced by the Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, the authority for the implementation of financial sanctions in the UK. It provides financial sanctions guidance for entities and individuals that operate in the sale or trade of high value goods, especially those trading internationally with regions that may be subject to UK financial sanctions restrictions.

    In short: if your business buys, sells, stores, insures, or transports high-value goods — art, luxury cars, precious metals, jewellery, fine wine — this document sets out your legal obligations under UK financial sanctions law.

    Who Does This Apply To?

    High Value Dealers (HVDs)

    A “high value dealer” is defined as a firm or sole trader that by way of business trades in goods (including an auctioneer dealing in goods), when the trader makes or receives, in respect of any transaction, a payment or payments in cash of at least £10,000 in total, whether the transaction is executed in a single operation or in several operations which appear to be linked. This refers to physical cash only and does not include bank transfers or digital payments.

    Art Market Participants (AMPs)

    An art market participant is defined as a firm or sole practitioner who is registered or required to register with HMRC as an art market participant under the Money Laundering Regulations. Their obligations apply when they trade in or act as an intermediary in art sales of £10,000 or more, or store works of art worth £10,000 or more for a single person.

    Both categories were added to the list of “relevant firms” subject to financial sanctions reporting requirements from 14 May 2025.

    Why Does This Sector Get Special Attention?

    The UK is a major international hub for the trade of high value goods, including art, antiques, luxury cars, precious metals and gemstones, and for investment in wines and whiskies. In 2023, global art sales were USD $65 billion and the UK had the third largest share at USD $11.05 billion, accounting for 17% of the world market.

    This scale, combined with the sector’s characteristics — high-value, portable, often privately traded — makes it attractive to sanctioned individuals seeking to move or hide wealth.

    How Sanctioned Persons Try to Exploit This Sector

    The guidance identifies several red flags to be aware of:

    Shell companies and intermediaries. Intermediaries and shell companies are often used to source, buy, or sell high value goods, and any associated payments. Such anonymity and obfuscation has been used to conceal the involvement of a designated person in a transaction.

    Asset movement. The movement of assets, including the sale of high value assets that were previously associated with a designated person, by family members or otherwise on their behalf, where funds are then disbursed offshore through secrecy jurisdictions, is an indicator suspected of being used to evade sanctions.

    Unclear payment sources. It may be indicative of sanctions evasion if there is a lack of clarity on the source of payment or funds, a concealment of the ultimate beneficial owner of the goods, transactions being made through offshore accounts, or a change in payment arrangements.

    Difficulty tracing goods. It is commonplace for goods to move between jurisdictions, making such movements less noteworthy when being done for the purposes of sanctions evasion — precious metals and stones in particular are very durable and effectively untraceable.

    Digital assets. Cryptocurrencies and NFTs may be used by designated persons in an effort to circumvent restrictions applied through financial sanctions. Those using, trading in and dealing with cryptocurrencies or NFTs are also subject to these regulations and must apply due diligence.

    What Are Your Main Obligations?

    1. Due Diligence

    The onus is on you to ensure that you have put in place sufficient measures to ensure you do not breach financial sanctions. Enhanced due diligence checks on your customers and payment chains may be needed.

    Practically, this means routinely checking the UK Sanctions List — not just when you start a new client relationship, but at every significant stage of a transaction, since the list is updated continuously.

    2. Reporting to OFSI

    Reporting obligations apply to relevant firms who are required to inform OFSI as soon as practicable if they know or have reasonable cause to suspect a person is a designated person or has committed a breach. When reporting to OFSI you must include the information or other matter on which the knowledge or suspicion is based, and any information you hold about the person by which they can be identified.

    If the suspect person is actually your customer, you must also report how much in funds or assets you are holding for them.

    3. Freeze and Stop

    If you discover a client or counterparty is sanctioned, you must immediately stop dealing with them, freeze any assets you hold on their behalf, and notify OFSI.

    4. Ownership and Control

    An asset freeze and/or some financial services restrictions may apply to entities or individuals which are owned, held or controlled, directly or indirectly, by a designated person. Those entities or individuals may not be designated in their own right, so their names may not appear on the sanctions list. However, those entities and individuals are also subject to financial sanctions.

    The ownership threshold that triggers this is more than 50% of shares or voting rights, or effective control of the entity.

    What Are the Penalties for Getting This Wrong?

    The consequences are serious. OFSI has powers to impose monetary penalties of up to £1 million or 50% of the total value of the breach, whichever is higher. Breaches of financial sanctions are also a serious criminal offence, punishable by up to 7 years imprisonment on conviction on indictment, and up to 12 months on summary conviction in England and Wales.

    Failure to comply with reporting obligations is itself an offence. A person who commits this offence is liable on summary conviction to imprisonment for a term not exceeding 6 months, or a fine, or both.

    The guidance includes a real-world case study: an investigation that concluded in 2023 found that around £1 million of artwork belonging to a US-sanctioned terrorist financier was being stored in warehouses in the UK. The artwork was seized and later forfeited by law enforcement under the Proceeds of Crime Act, and a man was arrested on suspicion of terrorist financing.

    Financial vs. Trade Sanctions — An Important Distinction

    OFSI deals with financial sanctions and the Department for Business and Trade (DBT) deals with trade sanctions. These different types of sanctions have differing processes, for instance in licensing activity. It is therefore important to consider the relevance of both financial and trade sanctions to your business.

    In practice: OFSI handles the “who” (frozen assets of designated persons), while DBT/OTSI handles the “what” (restricted goods and services). A business in the high-value goods sector may need licences from both.

    ⚠️ What Changed in the May 12, 2026 Update

    The guidance was updated on May 12, 2026 — the day before the Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026 came into force — to reflect one substantive legal change:

    The reporting threshold currency switched from euros to pounds sterling.

    Previously, the definitions of “high value dealer” and “art market participant” referenced a threshold of €10,000. 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.

    The guidance now reflects this: the £10,000 figure appears throughout sections 2.1 and 2.2 in place of the old euro amount.

    This aligns sanctions reporting obligations with upcoming changes to the UK’s money laundering regulations, so firms are not reporting in two different currencies. The Explanatory Memorandum describes this as a technical alignment measure rather than a change in policy, though the practical sterling equivalent of the old euro threshold will vary with exchange rates.

    Practical effect for businesses: If your compliance systems and internal policies referenced €10,000 as the trigger for cash-transaction reporting (HVDs) or art transaction/storage reporting (AMPs), they should now reference £10,000.

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  • Burning Question: What’s in The Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026?

    Here is a plain-language summary of the Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026 (S.I. 2026/443), which comes into force on 13 May 2026.

    What Is This Document?

    This is the official Explanatory Memorandum — essentially the government’s own plain-English explanation — for a package of amendments to 36 different UK sanctions regimes. It was prepared by the Foreign, Commonwealth & Development Office (FCDO). Think of it as a housekeeping and strengthening exercise: the government is not creating new sanctions programs, but is tightening, clarifying, and modernizing the rules across the board.

    The Key Changes, In Plain Terms

    1. New “End-Use Controls” on Exports — The Most Significant Change

    The regulations introduce a prohibition on UK exports of UK-sanctioned goods to a non-sanctioned third country where the government has determined there is a high risk that the goods will ultimately be diverted to a sanctioned jurisdiction.

    What this means in practice: Previously, if a UK business exported goods to, say, a country in Central Asia, and the UK government warned that those goods might end up in Russia, the business could legally proceed anyway. The previous policy was merely to engage relevant businesses and highlight the risk of diversion, which did not sufficiently mitigate the risk because a significant proportion of exporters chose to continue with the export even when they were not able to provide evidence that the risks had been mitigated.

    Under the new rules, once an exporter has been formally “informed” by the Secretary of State for Business and Trade of the diversion risk, they will be required to obtain an export licence before proceeding. The government will assess each application on a case-by-case basis and can refuse the licence if the diversion risk is not adequately mitigated.

    Why now? The greatest risk of diversion is currently to Russia. Despite UK bilateral trade in goods with Russia being down 97% compared with 2021, Russia and other sanctioned destinations are still managing to obtain items indirectly from the UK and allied nations. This measure responds directly to a government review published in May 2025 that recommended introducing exactly this kind of control.

    This applies across all UK sanctions regimes that include trade restrictions.

    2. Currency Change: Euros → Pounds Sterling for Reporting Thresholds

    The regulations update the definitions of “high value dealer” and “art market participant” within sanctions reporting requirements, so that monetary thresholds are expressed in pounds sterling rather than euros.

    What this means: Businesses such as high-end art dealers, jewellers, and luxury goods retailers who accept large cash payments have reporting obligations under both money laundering and sanctions rules. Those thresholds were previously set in euros (a legacy of EU membership). They are now being converted to pounds, aligning sanctions rules with the updated Money Laundering Regulations. This removes unnecessary complexity for firms subject to reporting requirements and supports clearer, more coherent regulatory expectations.

    3. Licensing Notices Can Now Be Sent Electronically Without Prior Consent

    Previously, sanctions regulations stipulated that electronic notices relating to licences could only be issued with the recipient’s prior consent. The regulations modernise these provisions by confirming that licensing authorities may issue notices electronically without prior consent.

    What this means: OFSI (the Office of Financial Sanctions Implementation, the UK’s sanctions licensing body) can now communicate with businesses by email as a matter of course, without first having to get prior consent that email is acceptable. A minor but practical modernisation.

    4. Broader Licensing for Pre-Existing Obligations (“Prior Obligations”)

    The regulations update the prior obligations licensing ground, which enables payments or transfers to satisfy obligations that arose before a person was designated under financial sanctions. The previous drafting was narrow, preventing the licensing of some legitimate pre-existing obligations and creating uncertainty for businesses and individuals.

    What this means: When someone gets added to the sanctions list, businesses they had prior contracts with sometimes need a licence to complete or settle those existing obligations (e.g., to pay a bill that predates the designation). The old rules were too restrictive, making it hard to get such licences approved. The amendment broadens the licensing ground so that under UK autonomous regimes, prior obligations may be met using any funds and by any person, including owned or controlled entities, enabling a wider range of legitimate prior obligations to be licensed while maintaining appropriate safeguards against sanctions circumvention.

    Note: this flexibility applies to UK-only (“autonomous”) sanctions regimes. Where UN Security Council resolutions are involved, the rules remain more restricted to comply with international obligations.

    5. Clarity on Treasury Debt Payments Through Long Payment Chains

    The regulations clarify that the existing exception for payments relating to UK government debt (Treasury debt) applies to all transfers of funds made as part of the payment chain, not just to direct payments from HM Treasury.

    What this means: Some UK government debt (such as gilts) may be held by sanctioned persons. There was ambiguity about whether intermediaries in a payment chain — banks passing payments along — were protected by the exception when making such payments. The amendment makes clear that the protection covers every link in the chain.

    6. Technical and Housekeeping Fixes

    Three further changes are purely technical:

    • Zimbabwe correction: A previous set of amendments incorrectly referred to “the Treasury” instead of “the Secretary of State” in Zimbabwe sanctions designation procedures. This is corrected to restore consistency across all UK sanctions regulations.
    • Russia and North Korea ship specification: Language in the Russia and DPRK sanctions regulations about the procedure for designating specific ships is being updated to reflect what was already enacted in the Economic Crime Act 2022, purely for clarity.
    • Sentencing provisions: Outdated wording about maximum prison sentences for customs-related sanctions offences is being removed. The Finance Act 2024 changed the relevant sentencing framework, making existing wording in sanctions regulations redundant. Sanctions offences of this nature will remain subject to a 10-year maximum imprisonment period.

    Who Is Affected?

    The regulations apply to the whole of the United Kingdom and also to conduct by UK persons where that conduct is wholly or partly outside the UK. A “UK person” includes both UK nationals and companies incorporated under UK law.

    The most practically significant impact is on exporters of goods to third countries who may need to be alert to end-use diversion risks. The estimated annual net cost to business is expected to be £0.1 million, with only a small number of additional exports expected to require licences. The government estimates the annual cost to the public sector (licensing and enforcement) at £1.4 million.

    Bottom Line

    This is a broad but largely technical update to the UK’s sanctions framework. The one genuinely new and substantive measure is the end-use export control — exporters of sanctioned goods to third countries can no longer simply ignore government warnings about diversion risk. Once officially notified of that risk, they must obtain a licence or stop the export. Everything else is clarification, modernisation, and consistency-tidying across a large number of existing sanctions regimes.

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  • May 12, 2026: OFSI makes regulatory updates

    Office of Financial Sanctions Implementation HM Treasury

    Changes to UK sanctions regulations – overview for firms

    We are writing to give you notice of changes made to the Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026. The regulations have now come into force.

    What’s changed 

    Changed 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 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 has been 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. 

    FAQs updated

     Further information can be found here 

    Here are the updated Frequently-Asked Questions:

    137. If I am a HVD carrying out a transaction over the value of £10,000 via card transaction, am I exempt from reporting requirements?  

    If you are a HVD, the relevant firm reporting requirement applies only when you make/ receive a payment (or payments) in cash of at least £10,000. This therefore does not include payments via bank transfer or digital payments.

    Amended on: 12 May 2026

    138. If I am an AMP carrying out a transaction over the value of £10,000 via card transaction, am I exempt from reporting requirements?  

    If you are an AMP, the reporting requirement applies regardless of how the transaction (or series of linked transactions) is made, where the transaction has a value of £10,000 or more.

    Amended on: 12 May 2026

    and the new one:

    185. The Prior Obligations licensing ground has been amended by The Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026. What has changed in practice?

    The prior obligations licensing ground enables payments or transfers to satisfy obligations that arose before a person was designated under financial sanctions. The Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026 amended this ground so that it is now applicable to a broader range of scenarios.  

    In practice, this expands the range of situations in which OFSI may consider licensing payments to satisfy prior obligations, subject to a case-by-case assessment. The change comes into force from 12 May 2026.  

    Under the amended ground: 

    1. It is no longer a condition that the funds or economic resources used to satisfy a prior obligation must be frozen under UK sanctions. 
    2. The limitations on whose funds or economic resources may be used (generally, those belonging to the DP or owned or controlled entity who owes the relevant prior obligation) have also been amended.  
    • For DPs under UK autonomous sanctions, those limitations have been removed.  
    • For UN DPs, where prior obligations licensing grounds apply, those limitations have been amended to allow the prior obligations of owned or controlled entities to be satisfied using the funds or economic resources of the DP, or of other owned or controlled entities. The assets of owned or controlled entities may also be used to satisfy prior obligations of the DP, as was the case previously. 

    Other limitations may apply, so it is important to check a specific regime to understand what may be permitted. For example, some regime-specific amendments have been made to the Iran Nuclear, Libya and DPRK regimes. Likewise, some regimes like Afghanistan do not have a prior obligation ground at all.  

    The changes do not mean that all payments relating to prior obligations will be permitted. OFSI retains discretion to refuse to grant a licence which falls within the relevant prior obligations ground even when the conditions are met, or to licence only a proportion of that obligation. For more information on OFSI’s licensing processes, please refer to our guidance.

    Added on 12 May 2026

    Here’s where those other links lead:

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  • May 11, 2026: … and an OFSI Iran sanctions update

    UK Gov logo, 50% resolution.png

    Today, Monday 11th May, the UK Government has designated the following 9 individuals and 3 entities under the Iran Sanctions Regime.

    Individuals designated:

    Name:Unique ID:
    Ekrem Abdulkerym OZTUNCIRN0268
    Namiq SALIFOVIRN0269
    Nihat Abdul Kadir ASANIRN0270
    Reza HAMIDIRAVARIIRN0271
    Farhad ZARRINGHALAMIRN0274
    Fazlolah ZARRINGHALAMIRN0275
    Mansour ZARRINGHALAMIRN0278
    Nasser ZARRINGHALAMIRN0279
    Pouria ZARRINGHALAMIRN0280

    Entities designated:

    Name:Unique ID:
    ZINDASHTI NETWORKIRN0272
    BERELIAN EXCHANGEIRN0273
    GCM EXCHANGEIRN0277

    The sanctions notice:

    Sanctions_Notice__Iran__11_May_2026Download

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  • May 11, 2026: OFSI makes updates to Russia sanctions

    UK Gov logo, 50% resolution.png

    Today, Monday 11 May, the UK Government has designated the following 63 individuals and 22 entities and under the Russia (Sanctions) (EU Exit) Regulations 2019. 

    Individuals designated: 

    Name:Unique ID:
    Yulia Sergeevna VELICHKO RUS3516
    Nadezhda Nikolaevna BOLTENKO RUS3517
    Andrey Alexandrovich USTINSKIKH RUS3581
    Grigory Alexandrovich GUROV RUS3585
    Vladislav Nikolaevich GOLOVIN RUS3584
    Mikhail Yuryevich DRUZHININ RUS3589
    Olga Sergeyevna DRUZHININA RUS3595
    Iryna Viktorivna KRAVCHENKO RUS3598
    Oleg Igorevich OVCHARENKO   RUS3518
    Dmitriy Evgenievich SHEVCHENKO   RUS3519
    Mikhail Alekseevich SHMOYLOVRUS3520
    Maksym Mykolayovych SHVETS RUS3521
    Mikhail Anatolyevich SURKOV RUS3522
    Vladislav Vadimovich IGIN RUS3523
    Artem Alekseevich MARFIN RUS3524
    Ekaterina Mikhailovna RUDKOVSKAYARUS3525
    Ekaterina Dmitrievna KURASHOVARUS3526
    Angelina Gennadyevna KUCHEROVARUS3527
    Ekaterina Alekseevna ANTIPOVARUS3528
    Irina Vasilyevna SURAZAKOVARUS3529
    Anton Andreevich PETROVRUS3530
    Yan Gennadyevich NALIMOVRUS3531
    Gulnara Vilsurovna ANDROSOVA RUS3532
    Igor Vladimirovich BOGATYREV RUS3533
    Armen Genrikhovich ASRIYANRUS3534
    Vladimir Igorevich GOLOVASHIN RUS3535
    Ilya Vladimirovich LIPKINDRUS3536
    Alexander Pavlovich KOCHETOVRUS3537
    Alexey Andreevich KLIMOVSKYRUS3538
    Dmitriy Anatolievich KHOKHLYUSHKINRUS3539
    Dmitriy Vasilyevich TKALYARUS3540
    Vladimir Viktorovich KREMLEVRUS3541
    Sergey Nikolaevich KORSUNRUS3542
    Sergey Evgenievich NAZIULINRUS3543
    Aleksandr Petrovich PRIGORNEVRUS3544
    Pavel Pavlovich DEMESHEVRUS3545
    Oleg Igorevich LUKYANENKORUS3546
    Kira Vadimovna NEKRASOVARUS3547
    Vladislav Alexandrovich POGREBNOY RUS3548
    Sergey Vyacheslavovich TATTIRUS3549
    Daria Sergeevna LAVRIKOVARUS3550
    Yuliya Vitalyevna POGREBNAYARUS3551
    Olga Alexandrovich POLOSINARUS3552
    Elizaveta Alekseevna FETISOVARUS3553
    Viktoriya Igorevna GORDEEVARUS3554
    Maria Sergeevna KUZNETSOVARUS3555
    Alina Maratovna GABIDULLINARUS3556
    Vladimir Aleksandrovich TROSHIN RUS3557
    Evgeniya Valentinovna LUSS RUS3586
    Denis Maksimovich DOLGOV RUS3558
    Alina Vladimirovna KOPYTOVA RUS3559
    Dmitriy Valeryevich LUKIENKO RUS3560
    Mikhail Alexandrovich BARAEV RUS3561
    Viktor Nikolaevich OSTRESHKO RUS3562
    Anastasia Olegovna KAZAKOVA RUS3563
    Anastasia Vadimovna ALTUNINA RUS3564
    Timofey Alekseevich BELOV RUS3565
    Alexey Vladimirovich MEDVEDEV RUS3566
    Mikhail Vladimirovich BIYUN RUS3567
    Anna Vladimirovna ANTIPOVA RUS3568
    Irina Vladimirovna NIKITYUK RUS3569
    Vladimir Grigorievich TABAK RUS3572
    Timofey Vladimirovich VASILIEV RUS3573

    Entities Designated: 

    Names:Unique ID:
    THE  CENTRE FOR MILITARY-SPORTS TRAINING AND PATRIOTIC UPBRINING OF THE YOUTH “WARRIOR”RUS3582
    CENTRE FOR THE STUDY OF THE YOUTH ENVIRONMENT AND MONITORING OF NETWORKSRUS3583
    LLC “ITS SEVGU”RUS3577
    STATE BUDGETARY INSTITUTION OF THE REPUBLIC OF CRIMEA “CLINICAL SANATORIUM FOR CHILDREN AND CHILDREN WITH PARENTS “ZDRAVNITSA”RUS3578
    OOO “Art-Kvest”RUS3591
    GAU MTs “Selet – AK Bars”RUS3592
    FGBU DOP “ROSSIYA”RUS3593
    GUP RK “SOLNECHNAYA TAVRIKA”RUS3594
    DOL “ZHEMCHUZHINA”RUS3600
    OOO “DOLP IM. A.V. KAZAKEVICHA”RUS3599
    GBUZRK “CHILDREN’S HOUSE “YOLOCHKA”RUS3601
    FGBU “DOP “RADUGA”RUS3588
    FEDERAL STATE AUTONOMOUS EDUCATIONAL INSTITUTION OF HIGHER EDUCATION “SEVASTOPOL STATE UNIVERSITY”RUS3590
    GBUZRK “KPB No 5”RUS3596
    LLC “TSRIPTB”RUS3597
    GBU DO RK “DOTs “Alyye Parusa”RUS3579
    INTERNET DEVELOPMENT INSTITUTERUS3574
    EUROVIEWRUS3575
    GOVORITRUS3576
    ANO STRATEGIC COMMUNICATIONS CASPIAN 2030RUS3570
    EXPERT INSTITUTE FOR SOCIAL RESEARCHRUS3571
    SONGDOWON INTERNATIONAL CHILDREN’S CAMPRUS3580

    here’s the sanctions notice:

    Sanctions_Notice__Russia__11_May_2026Download

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  • May 11, 2026: A decade of OFSI… a blog post

    Office of Financial Sanctions Implementation HM Treasury
    Marking 10 years of OFSI: partnership, progress and the future of financial sanctions At the end of April, OFSI marked its 10th birthday by hosting an international conference on financial sanctions at HM Treasury, bringing together partners from across government, industry and international organisations. Thank you to everyone who attended and contributed to the discussion. 

    The event reflected on how UK financial sanctions have evolved over the past decade, and the role they play in an increasingly complex global environment. 
    Key themes included: 
    – Our new PERC strategy (Promote, Enable, Respond, Change) and how it is being delivered in practice  
    – The importance of partnerships across government, industry and international allies  
    – The opportunities and risks presented by technological change  

    Discussions reinforced that sanctions are most effective when delivered collectively, through strong coordination, clear implementation and ongoing engagement.

    OFSI published the following blog post about the event:

    Marking 10 years of OFSI: partnership, progress and the future of financial sanctions 

    Lindsey Whyte, Director General for International at HM Treasury, delivering remarks at OFSI10. Picture by Simon Walker / HM Treasury

    What does a decade of UK Financial Sanctions look like in practice? At the end of April, to mark its 10th anniversary, OFSI hosted an international conference on sanctions, bringing together partners and stakeholders from across UK government, industry and international allies including the EU, US, Ukraine, Australia, Japan, Canada and the Cayman Islands. 

    The conference demonstrated OFSI’s ability to convene a cross-sector group of partners, and, as many attendees noted, this created a more distinct forum than is typical. By bringing these partners together in one forum, OFSI had the unique opportunity to set out its new strategy openly, to support practical discussions on the shared challenges facing the sanctions community and pointing towards a clear pathway to strategically address these.  

    In her address, Lucy Rigby MP, Economic Secretary to the Treasury and OFSI’s lead Minister, emphasised that sanctions are not just about imposing restrictions, they also protect the integrity of the UK’s financial system and help ensure legitimate businesses are not undercut by illicit actors. Describing financial sanctions as an integral part of the UK economy, she underlined their role in supporting national resilience and maintaining the UK’s global reputation. She also pointed to a more complex geopolitical landscape, with links between developments in Russia and the Middle East, and the need to maintain sustained pressure on Russia for its illegal war in Ukraine, while managing wider risks to the global economy. She highlighted the importance of making better use of data and continuing to work collectively as threats evolve. 

    This direction was echoed by Lindsey Whyte, HM Treasury’s Director General International, and Permanent Secretary James Bowler, who both reflected on the strain on the international order and the central role sanctions now play, which require strong partnerships across government and with industry nationally and internationally.  

    The evolution and importance of the UK sanctions regime   

    Over the course of the day, panels explored how the UK’s sanctions framework has evolved and where it goes next. The first session, moderated by OFSI Deputy Director Daniel Drake, reflected on the shift from operating through the EU to delivering an autonomous UK framework. This capability was tested at pace in February 2022, when more sanctions were introduced in a few months than in the previous decade, driving significant change across government and industry. 

    As Daniel noted, OFSI is now “entering its teenage years” with stronger capabilities, deeper partnerships, and a clear role in delivering national security outcomes. 

    Across industry and international perspectives, what came through clearly was how much the system has matured. Firms described a shift from basic screening to highly sophisticated, proactive approaches, while international partners highlighted the UK’s credibility across implementation and enforcement. At the same time, the landscape continues to change, with increasing legal complexity, more sophisticated evasion tactics and ongoing pressure to strengthen capability and technology.

    Picture by Simon Walker / HM Treasury

    The Industry Perspective 

    The industry panel, moderated by OFSI Deputy Director Beth Davies, offered a candid view of how sanctions are applied in practice. Panellists highlighted the scale of investment firms have made in building sanctions capability, alongside the challenge of operating in a changing environment, where certainty is not always clear-cut and professional judgement is often required. Visible enforcement is seen as critical in shaping behaviour, while continued dialogue between government and industry remains essential, particularly in managing overcompliance and ensuring policy intent is understood. 

    Partnerships at the core of sanctions delivery 

    The penultimate panel, moderated by OFSI Director Giles Thomson, highlighted the importance of international partnerships for the effectiveness of sanctions. Speakers from the US, EU and Cayman Islands were clear that sanctions are most effective when applied collectively. Alignment across jurisdictions increases impact, whilst practical cooperation through intelligence sharing and regular engagement underpins delivery. Maintaining this alignment requires constant effort, particularly as new challenges emerge, including dynamic evasion techniques and the growing use of crypto assets. 

    Looking ahead: the next decade of sanctions 

    The final panel looked ahead to the future. Speakers focused on how technology will shape the future of sanctions. Advances in artificial intelligence and data are creating new opportunities to strengthen analysis, coordination and decision-making. However, panellists noted the need to be accountable for using these tools carefully, ensuring speed and scale does not come at the expense of sound human judgement.  The discussion highlighted a more complex operating environment, where sanctions, anti-money laundering and fraud are increasingly interconnected. The conclusion was clear: rapid technological change will demand that the system modernises ways of working to keep ahead of circumvention and evasion, and to take full advantage of new capabilities to deliver greater impact, without losing the role of human judgement.

    How OFSI delivers: PERC in action 

    A consistent thread running through the day was how the four pillars of OFSI’s new strategy –  Promote, Enable, Respond and Change (PERC) – are being delivered in practice.  

    The licensing spotlight highlighted the importance of enabling legitimate activity whilst maintaining pressure on designated targets, supported by clearer guidance, targeted use of General Licences and a structured prioritisation approach. The enforcement session reinforced the value of visible action in driving compliance, with more targeted investigations and increased publication of outcomes helping to shape behaviour across the system. 

    Feedback since the event has reinforced the value of bringing together such a broad mix of partners, allowing for what many commented felt like a different kind of conference. The range of perspectives and experience ensured meaningful, open, practical discussions about shared challenges and the future of sanctions throughout the day. 

    Closing the conference, Director Giles Thomson reflected on both progress across the decade, and the importance of maintaining momentum: “Financial sanctions are, at their core, a collective endeavour. They are only as strong as the system that implements them, and that system only functions because of the people within it. “

    The pace of change since 2022 has been significant, but the foundations now in place leave the UK well positioned for the future. Ultimately, the day reinforced a simple point: sanctions are not delivered by any one organisation alone. Their effectiveness depends on the collective efforts of government, industry and international partners and it is that shared effort which will define the next decade as much as the last. 

    To learn more about OFSI’s strategy and our Promote, Enable, Respond and Change (PERC) framework, read the full document here: OFSI Strategy: 2026 – 2029 – GOV.UK 

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  • May 5, 2026: OFSI’s Global Irregular Migration and Russian program listings updated

    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:

    Sanctions_Notice__Global_Irregular_Migration__05_May_2026Download

    and Russia:

    Sanctions_Notice__Russia__5_May_2026Download

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  • April 29, 2026: OFSI plays UN catchup (Sudan, Afghanistan/Taliban), and then some (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:

    Sanctions_Notice__Sudan__29_April_2026Download

    Afghanistan/Taliban:

    Sanctions_Notice__Afghanistan__29_April_2026Download

    and Russia:

    Sanctions_Notice__Russia__29_April_2026Download

    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?

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  • April 24, 2026: OFSI issues new GL and makes some FAQ changes

    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:

    INT.2026.9512597_PNDownload

    and the General Licence:

    INT.2026.9512597_GLDownload

    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

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