The Office of Financial Sanctions Implementation (OFSI) has amended General Licence INT/2025/7628424 on 28 October 2025 to simplify the definitions of 'UK Employees' and 'UK Directors' and provide additional clarity regarding which individuals could receive payments under the licence. The amendment relates to a licence issued under the Iran (Sanctions) (Nuclear) (EU Exit) Regulations 2019 that permits designated Iranian entities, including Bank Melli, Bank Saderat Iran, Bank Tejarat, Persia International Bank Plc, and Iran Insurance Company, to make specific payments for remuneration, pensions, IT services, and accountancy services. The licence originally took effect on 23 October 2025 and expires on 22 April 2026, with the definitional amendments intended to clarify payment eligibility criteria for UK-based employees and directors of the designated entities and their subsidiaries.

The Office of Financial Sanctions Implementation (OFSI) has amended General Licence INT/2025/5635700 for Russian Oil Exempt Projects to add the Kurdistan Export Pipeline as an Exempt Project. Business operations relating to the Kurdistan Export Pipeline are permitted from 31 July 2026 until 14 October 2027.

The Office of Financial Sanctions Implementation (OFSI) has amended the Oil Price Cap: Exempt Projects and Countries General Licence INT/2022/2470156 and the Russian Oil Exempt Projects General Licence INT/2025/5635700. The publication notice for INT/2025/5635700 confirms that the Sakhalin-2 exemption was extended on 1 October 2026, with the amended licence providing for the exemption to run until 31 December 2026. The amended INT/2022/2470156 likewise permits specified supply or delivery by ship of Russian oil originating in or consigned from the Sakhalin-2 Project to Japan until 31 December 2026, subject to the licence conditions. Use of each licence remains subject to its respective conditions and record-keeping requirements.

The Office of Financial Sanctions Implementation (OFSI) has amended General Licence INT/2026/8893924, introducing a monthly reporting requirement for designated persons relying on the licence. Designated persons must now provide HM Treasury with a report within 14 days of the end of each calendar month, detailing all activities and/or payments carried out under the licence during that month. The expiry date of the General License was also extended from 6 July 2026 to 7 October 2026.

The Office of Financial Sanctions Implementation (OFSI) has amended and extended General Licence INT/2026/8893924 under regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019, SI 2019/855. General Licence INT/2026/8893924 permits the winding down of insurance and reinsurance contracts involving Maritime Mutual Association Limited, Maritime Mutual Insurance Association (NZ) Limited and their subsidiaries. The amendments allow relevant UK institutions to process qualifying overseas wind-down payments relating to written insurance or reinsurance contracts entered into before 24 February 2026. The General Licence has been extended to expire at 23:59 on 6 October 2027.

The Office of Financial Sanctions Implementation (OFSI) has amended section 6.21 of the UK financial sanctions general guidance, updating the HM Treasury debt exception applicable to certain UN designated persons (UN DPs). The amendments expand the sanctions regimes covered by the exception to include the Iran (Sanctions) (Nuclear) (EU Exit) (Amendment) Regulations 2025 and further clarify the circumstances in which payments relating to HM Treasury debt may be made without a licence, including certain indirect payment arrangements involving obligations connected with UN DPs. The revised guidance also provides additional detail on the reasonable steps expected of persons relying on the exception, including in relation to payment-chain verification, prior obligations, specified accounts and corresponding jurisdictions.

The Office of Financial Sanctions Implementation (OFSI) has announced amendments to two general licences. The changes affect Licence INT/2025/5635700 and Licence INT/2022/2470156, both of which relate to Russian sanctions implementation. The amendments modify existing permissions regarding oil price caps and exempt projects.

The Office of Financial Sanctions Implementation (OFSI) and HM Treasury (HMT) have updated the Tier 2/3 notification that Tier 1 Provider has not confirmed compliance with reporting requirements under INT/2022/2469656 form, as part of their guidance on the Russian Oil Services ban.

The Office of Financial Sanctions Implementation (OFSI) has announced the extension of the Frozen Assets Review deadline to 11 November 2024. The notice provides background and guidance for the 2024 frozen asset reporting exercise, which HM Treasury carries out yearly to update records so that they reflect any changes made to accounts during the reporting period.

The Office of Financial Sanctions Implementation (OFSI) has issued new General licence INT/2025/6135848, updated INT/2025/6160920 and amended licence INT/2025/5855272. General licence INT/2025/6135848 permits asset and liability transfers for the UBS-Credit Suisse integration under Russia sanctions regulations. General licence INT/2025/6160920 updates the framework for legal services, replacing the previous licence. OFSI also amended licence INT/2025/5855272 to include the International Maritime Organisation in permitted membership fee payments to international organisations.

Corporate Crime analysis: On 21 March 2025, the Office of Financial Sanctions Implementation (OFSI) published its Annual Review for 2023-2024, titled ‘Engage, Enhance, Enforce’ (the Review). The annual review, now in its eighth edition, is intended to provide an overview of OFSI’s operations in the past financial year. A change in title for this year’s review (the previous two years’ were titled ‘Strengthening our Sanctions’) is illustrative of an evolution in the government’s sanctions strategy, with an increasing emphasis on enforcement to drive sanctions compliance. The growing maturity of the UK’s autonomous sanctions framework, and the increasing allocation of government resources, have facilitated a shift in strategy from a predominant focus on implementation towards the multi-pronged approach embodied in the title of this year’s review. The widespread implementation of sanctions measures since 2022 provided the catalyst for the development of the UK’s autonomous sanctions regime. The content of the annual review is structured into a section for each of the three limbs (engage, enhance and enforce), as summarised in turn below. Written by Alexander Gorst, senior associate, and Mohamed Naleemudeen, associate, at BCL Solicitors LLP.

The Office of Financial Sanctions Implementation (OFSI) has released its annual review 2023-2024, reporting that £25bn of Russian assets have been frozen since February 2022 and there have been 396 enforcement cases. The review details OFSI's first proactive monetary penalty, use of its disclosure power, and first counter-terrorism designation as well as that staff numbers have increased to 135, while 564 new designated persons were added to sanctions lists. The report highlights enhanced enforcement capabilities and expanded international cooperation.