On 15 May, the UK Government published a policy review of sanctions implementation and enforcement.

The UK Government has emphasised that sanctions are a vital foreign policy and national security tool, and the Sanctions and Anti-Money Laundering Act 2018 (“SAMLA 2018”) allows the government to impose, enforce and lift sanctions. In 2025, the National Crime Agency (“NCA”) has secured its first conviction for breaches of UK sanctions against Russia, and the Office of Financial Sanctions Implementation (OFSI) has imposed a monetary penalty of £465,000 for breaches of financial sanctions.

The Government has outlined future steps related to sanctions implementation, which include improvement and facilitation of compliance, and effective enforcement, which will involve the use of both, criminal and civil powers. It is noted that “criminal prosecution will not always be the optimal approach” and that civil enforcement can be equally effective in some cases. As such, the Government intends to open public consultations in order to assist with the development of:

1. an early civil settlement scheme for breaches of financial sanctions, and
2. an accelerated civil penalty process for certain financial sanctions breaches.

A cross-government strategy on sanctions enforcement will be published in due time along with regular updates on the actions taken.

Ownership and control concepts continue to represent challenges for businesses and require complex due diligence. The Government has pledged to provide further guidance on ownership and control. It is also committed to continue engagement with industry to ensure compliance.

The review contains two annexes:

1. Annex 1 outlines the roles and responsibilities of those in charge of sanctions regime design, strategy and implementation. The Foreign, Commonwealth & Development Office is responsible for overall sanctions policy, including designations decisions. However, there are a few other Government agencies overseeing sanctions implementation, including licencing, engagement and guidance. Those agencies include:

• Office of Trade Sanctions Implementation, Department for Business and Trade – for trade sanctions.
• Office of Financial Sanctions Implementation, HM Treasury– for financial sanctions.
• Department for Transport – for transport sanctions.
• Home Office – for immigration sanctions.

The same government departments and agencies are responsible for civil enforcement of sanctions, i.e. investigations and civil monetary penalties. However, the responsibility for criminal enforcement lies with the HM Revenue and Customs, the National Crime Agency, Home Office, Police and the Serious Fraud Office.

2. Annex 2 defines main themes for external engagement, focusing on continuous engagement between the government and businesses, greater clarity of the sanctions purposes and investment in sanctions resources and expertise.

The policy paper has reiterated that compliance is key – this message echoes across various recent UK Government documents. Businesses have different levels of sanctions exposure and shall remain vigilant when it comes to compliance. It is important to have compliance policy in place and ensure that your business has implemented relevant systems, including employees training.

How Gherson can assist

The Gherson team have years of experience advising on compliance matters, including sanctions. We regularly advise clients on sanctions laws and can assist companies develop policies and systems aimed at prevention of sanctions risks.

If you have any questions arising from this blog, please do not hesitate to contact us for advice, send us an e-mail or, alternatively, follow us on X, Facebook, Instagram or LinkedIn to stay-up-to-date.

The information in this blog is for general information purposes only and does not purport to be comprehensive or to provide legal advice. Whilst every effort is made to ensure the information and law is current as of the date of publication it should be stressed that, due to the passage of time, this does not necessarily reflect the present legal position. Gherson accepts no responsibility for loss which may arise from accessing or reliance on information contained in this blog. For formal advice on the current law please do not hesitate to contact Gherson. Legal advice is only provided pursuant to a written agreement, identified as such, and signed by the client and by or on behalf of Gherson.

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