Contents Introduction Why sanctions compliance is a board-level issue The UK sanctions framework in brief Ownership and control risk Screening and due diligence Red flags and high-risk scenarios Reporting obligations and OFSI investigations Civil and criminal liability Cross-border exposure and secondary risk Frequently asked questions How Gherson can help 1. Introduction Sanctions compliance is no … Continued
On 3 March 2026 the Central Bank of Russia announced that it had initiated proceedings before the General Court of the European Union challenging the EU’s decision to indefinitely immobilize approximately EUR 210 billion in Russian sovereign assets held in the EU. 1. Background: The EU’s Indefinite Asset Freeze In December 2025, the EU adopted … Continued
On 19 February 2026, LITASCO SA, a Geneva-based company and international trading arm of a Russian major oil company, LUKOIL, filed a notice of dispute to the Republic of Bulgaria. As grounds of dispute, the notice refers to the Agreement between Switzerland and Bulgaria on the Promotion and Mutual Protection of Investments, signed in October … Continued
Contents Introduction On what basis can someone be sanctioned? What options are available to challenge a designation? Ministerial review: the first step Court challenges and judicial review Evidential issues and closed material Strategic considerations before challenging Licensing while a challenge is ongoing Frequently asked questions How Gherson can help 1. Introduction Being designated under the … Continued
Gherson successfully represented our sanctioned client in the Court of Appeal, which found that our client had not been validly served with a claim form at his London property. Mikhail Fridman v Agrofirma Oniks LLC & Anor-[2026] EWCA Civ 139
Contents 1. Introduction 2. What does it mean to be subject to UK sanctions? 3. Types of UK sanctions measures 4. Immediate consequences of designation 5. Asset freezes in practice 6. Impact on businesses and third parties 7. Criminal and civil enforcement risks 8. Can UK sanctions be challenged? 9. Licensing and exceptions 10. Frequently … Continued
OFSI and partners clamp down on the abuse of cryptoassets In July 2025, the Office of Financial Sanctions Implementation (OFSI) published its Cryptoassets Threat Assessment (the “Threat Assessment”), which we previously examined in detail in our article titled “OFSI’s Cryptoassets Threat Assessment, July 2025: key risks and compliance gaps”. Prior to this, on 11 March … Continued
This article by Roger Gherson, published in Financial Regulation International, considers recent UK Supreme Court case law concerning the relationship between the courts, Parliament and the executive, with particular focus on sanctions-related decisions. It outlines the Supreme Court’s approach to reviewing government decision-making in complex areas such as foreign policy and financial sanctions and reflects on how constitutional principles, … Continued
The recent Supreme Court judgment in Shvidler v Secretary of State has far-reaching implications for the UK’s sanctions framework. By expanding ministerial discretion in sanctions cases, the decision raises concerns about the balance between executive power and judicial review. In this article, Roger Gherson, Senior Partner of Gherson Solicitors LLP, shares his thoughts on whether … Continued
In a notable judgment handed down by Mr Justice Bright on 31 July 2025 in LLC EuroChem North-West 2 & Ors v Société Générale S.A. & Ors [2025] EWHC 1938 (Comm), the English High Court addressed the enforceability of on-demand bonds in the context of EU sanctions. The case revolved around six English-law governed bonds issued … Continued
The Supreme Court issued an important judgment involving designated persons, rejecting the argument that the UK Government acted unlawfully. In two cases – Shvidler (Appellant) v Secretary of State for Foreign, Commonwealth and Development Affairs (Respondent); and Dalston Projects Ltd and others (Appellants) v Secretary of State for Transport (Respondent), the Supreme Court considered the … Continued
Earlier this year, the UK Government announced the creation of a new sanctions regime targeting irregular migration and organised immigration crime (please see our previous blog). On 23 July 2025, the UK Government imposed sanctions under the new regime for the first time. The sanctions targeted 20 individuals and 5 entities involved in people smuggling, … Continued