The UK’s latest sanctions measures signal a significant shift in how regulators view the role of crypto-assets in sanctions compliance and enforcement. Originally published in Law360, Thomas Cattee, Partner and Head of White-Collar Crime at Gherson LLP, examines how the UK’s latest sanctions package reflects increasing regulatory scrutiny of crypto exchanges, payment networks and digital … Continued
The Plan President Ursula von der Leyen announced a new proposal of an entry ban on any individual who served as a Russian soldier in the war against Ukraine since it began in February 2022. The aim is to ensure that Europe is ‘off-limits’ to anyone who took part in the invasion, and to dissuade … Continued
Roger Gherson, Senior Partner at Gherson Solicitors LLP, comments in The Legal Diary on the UK Government’s latest sanctions package, targeting cryptocurrency networks and financial institutions linked to Russia. “The most recent package of sanctions targets financial institutions and crypto networks demonstrating that the UK Government remains fully committed to using this largely political tool … Continued
On 23 April 2026, the UK Government announced the introduction of the Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026 (“the Regulations”), due to come into effect on 13 May 2026. The prior obligations licensing ground Of particular interest are the changes made to the prior obligations licensing ground. This ground enables a designated individual to … Continued
Roger Gherson, senior partner at Gherson Solicitors LLP, comments in Compliance Week on the UK and EU’s commitment to extending Russian sanctions and strengthening enforcement. “Roger Gherson, senior partner at Gherson Solicitors LLP, said that OFSI’s new guidance on the civil enforcement of financial sanctions introduces several key changes to create a “quicker, easier and … Continued
“The UK’s Office of Financial Sanctions Implementation (OFSI) has updated its guidance on the civil enforcement of financial sanctions, introducing several key changes to create a “quicker, easier and more transparent” process. The revisions are aimed at addressing an increase in the volume and complexity of OFSI’s enforcement work and stem from a consultation process … Continued
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