HMRC concludes a compound settlement for breaches of Russian sanctions

By Anna Tsereteli

On 8 July, HM Revenue and Customs (HMRC) published their Notice to Exporters: NTE 2025/18 as relate to the compound settlement of £1,160,725.67 with the UK exporter that made goods available to Russia in violation of the Russia (Sanctions) (EU Exit) Regulations 2019. The compound settlement, which was paid to HMRC in May 2025, is the … Continued

OFSI updates its Guidance on Financial Sanctions FAQs

By Anna Tsereteli

On 3 July, the Office of Financial Sanctions Implementation (“OFSI”) updated its UK Financial Sanctions FAQs Guidance by adding 4 new FAQs – 149, 150, 151 and 152, and withdrawing FAQs 123 and 124. FAQ 149 provides a definition of economic resources which are assets of every kind and may include: precious metals or stones, … Continued

US and UK regulators issue licences pertaining to Russia-related energy projects

By Anna Tsereteli

On 27 June 2025, OFSI amended General Licence INT/2025/5635700 and General Licence INT/2022/2470156 as relate to an exemption on the restrictions of oil supplies coming from the Sakhalin-2 project, which is an oil and gas development in Sakhalin island, Russia  Further, on the same day, OFAC issued  General License No. 115B authorising certain transactions relating … Continued

The EU extends sectoral Russia-related sanctions by further six months

By Anna Tsereteli

On 30 June 2025, the Council of the EU announced the extension of the EU’s restrictive measures in relation to Russia’s activities in Ukraine by further six months until 31 January 2026. The range of sectoral measures is set out in Council Decision 2014/512/CFSP of 31 Jul 2014 (as amended) and includes restrictions on trade, … Continued

Sanctions threat assessment: OFSI issues Art Market Participant and High Value Dealers threat assessment

By Anna Tsereteli

On 18 June 2025, HM Revenue and Customs and the Office of Financial Sanctions Implementation HM Treasury (“OFSI”) issued a threat assessment (the “Threat Assessment”) covering threats to financial sanctions compliance relevant to Art Market Participants (“AMPs”) and High Value Dealers (“HVDs”). On 14 May 2025, AMPs and HVDs became ‘relevant firms’ (as defined in … Continued

Keir Starmer — ‘be careful what you wish for’ | Daily Star

By Anna Tsereteli

Roger Gherson, Senior Partner at Gherson Solicitors LLP comments in the Daily Star on the escalating risks of the UK’s current sanctions approach to Russia: “It is widely accepted that on the whole sanctions are not working. They were intended to weaken Russia’s economy and force the Kremlin to change its policy towards Ukraine. The opposite has happened.” … Continued

GVA Capital Ltd to pay fine for violations of OFAC sanctions and reporting obligations

By Anna Tsereteli

On 12 June, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) reported that it had a imposed a civil monetary penalty of USD 215,988,868 against GVA Capital Ltd for violations of US sanctions against Russia and related failures in reporting obligations. GVA Capital Ltd is a venture capital firm based in … Continued

OFSI amends General Licence on insolvency-related payments and activities involving GTLK companies and their subsidiaries

By Anna Tsereteli

On 12 June 2025, the Office of Financial Sanctions Implementation (“OFSI”) amended its General Licence INT/2023/3263556: GTLK Companies and their Subsidiaries – Insolvency-related payments and activities (“General Licence”). GTLK JSC is Russia’s largest leasing transport company which was designated by the UK Government in April 2022. Its associated entities include GTLK Europe and GTLK Capital; … Continued

The UK sanctions regime – International Accountant

By Gherson Solicitors

Roger Gherson and Caroline Black ask whether the UK sanctions regime is fit for purpose in their article published in International Accountant. They explore the UK’s Global Anti-Corruption sanctions framework and its alignment with the rule of law, highlighting serious concerns about the low threshold for designation, lack of independent oversight, and the human rights implications for … Continued

EU Court in Luxembourg confirms the ban on export of euro banknotes to finance medical treatment in Russia

By Gherson Solicitors

On 30 April 2025, the Court of Justice of the European Union confirmed that export by a person travelling to Russia of euro-denominated banknotes for the purposes of financing medical treatments is prohibited as such treatments do not meet needs occasioned by that person’s travel or stay in Russia. Background On 1 March 2022, the … Continued

The Bank of Georgia restricts purchases for Russians exceeding EUR 300

By Gherson Solicitors

It has been reported this week that the Bank of Georgia introduced a restriction for Russian nationals with the Bank of Georgia accounts in regard to purchases worth more than EUR300 in compliance with international sanctions. According to Article 3h of the European Union Regulation No 833/2014 as amended by Regulation (EU) 2022/428, it is … Continued

UK Government updates its guidance on reporting on breaches of trade sanctions and new law on disclosure is laid in Parliament

By Gherson Solicitors

On 21 May 2025, the Department for Business Trade and Office of Trade Sanctions Implementation (“OTSI”) updated their guidance Report a suspected breach of trade sanctions by adding ‘Whistleblowing for trade sanctions’ section. From 26 June 2025, a worker can report about a person or business they think is committing a breach of trade sanctions … Continued