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
On 17 July 2025 the Office for Financial Sanctions Implementation (“OFSI”) launched new online reporting and licensing forms, seeking to improve efficiency and reduce processing times for its services. The original procedures for submitting forms will remain in operation, and the use of the online forms is not currently mandatory. However, OFSI is encouraging the … Continued
On 18 July 2025 the EU agreed its 18th sanctions package against Russia. This latest round of EU sanctions will lower the G7’s crude oil price cap from the current $60.00 per barrel to $47.60 per barrel. The price cap will be revised every six months in order for it to adapt to any changes … Continued
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
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
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
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