UK Weekly Sanctions Update - Week of July 28, 2025

Russia sanctions

• OFSI issues £300k monetary penalty for UK sanctions breaches: On July 31, 2025, OFSI announced that it had issued a £300,000 penalty against Markom Management Limited (“MML”) for its instruction of a £416,590.92 payment on February 20, 2018, from another company’s bank account with the knowledge that the recipient was a designated person, having failed to put in place adequate compliance and controls procedures.  OFSI outlines some key lessons for industry, including that all firms, regardless of their size, should take appropriate steps to understand and address their exposure to sanctions risks; have adequate sanctions processes to ensure compliance including to promptly identify as well as report suspected breaches of financial sanctions to OFSI; and be alert to the risks of making payments in haste. (https://assets.publishing.service.gov.uk/media/688b92af6c7eb66caea94df3/Penalty_Publication_Notice_-_MML.pdf; https://www.gov.uk/government/news/penalty-issued-for-breach-of-russia-sanctions)
• EuroChem loses EUR 212 million High Court case against SocGen and ING: On July 31, 2025, the UK High Court dismissed a claim by EuroChem against SocGen and ING for receipt of certain bond payments.  In dismissing the claim, Bright J found that Andrey Melnichenko, a UK assets freeze target, held ‘de facto control” of the EuroChem entity that would benefit from the bonds. (https://www.oeclaw.co.uk/images/uploads/judgments/2025.07.31_Approved_Judgment__2025__EWHC_
  1938_%28Comm%29_.pdf)
• UK government amends one entry on the UK sanctions list under the Russia regime: On July 31, 2025, the UK government amended the entry for Petr Aven on the UK sanctions list under the Russia regime. (https://assets.publishing.service.gov.uk/media/688b5a2e15968f11ced5b808/Notice_Russia_310725.pdf)
• UK Supreme Court dismisses Shvidler and Dalston Projects de-listing appeals: On July 29, 2025, the UK Supreme Court dismissed appeals by Eugene Shvidler and Dalston Projects Ltd against sanctions imposed against them.  The Court agreed that the sanctions had interfered with the appellants’ private lives under Article 8 of the ECHR, but rejects that those interferences were disproportionate and unlawful. (https://supremecourt.uk/uploads/uksc_2024_0045_0055_judgment_b490db4480.pdf)

Cyber Sanctions

• UK government updates 19 entries on the UK sanctions list under the Cyber regime: On July 31, 2025, the UK government updated the entries of 18 individuals and one entity on the UK sanctions list under the Cyber Regime. (The UK Sanctions List - GOV.UK)

Other Sanctions

• Palestine Action wins permission to challenge proscription as terrorist organisation:  On July 30, 2025, the UK High Court granted permission for Huda Ammori, co-founder of NGO Group Palestine Action, to challenge the proscription of Palestine Action as a terrorist organisation under the Terrorism Act 2000. Palestine Action was proscribed on July 5, 2025. (https://www.judiciary.uk/wp-content/uploads/2025/07/Ammori-v-SSHD-Approved-Judgment-300725.pdf)
• UK government updates UK support to Ukraine: factsheet: On July 29, 2025, the UK government published and updated factsheet summarising how the UK is supporting Ukraine following the Russian invasion. (UK support to Ukraine: factsheet - GOV.UK)
• ECJU publishes Notice to Exporters on updated end user undertaking (EUU) and guidance: On July 29, 2025, the ECJU published NTE 2025/20 which amends the end user undertaking (EUU) form for a standard individual export licence (SIEL), standard individual trade control licence (SITCL) or a licence to provide technical assistance. (NTE 2025/20: updated end user undertaking (EUU) and guidance - GOV.UK)ECJU publishes updates on guidance for Exporting items on the ‘Trigger List’: On July 29, 2025, the ECJU updated its guidance for items on the ‘trigger list’ to state that all end-users (including stockists) should now complete the new end-user undertaking. The guidance relates to the export of certain nuclear equipment, material and technology.  (Exporting items on the ‘Trigger List’ - GOV.UK)
• UK publishes new guidance on sanctions risks for Middle East charities: On July 24, 2025, the UK’s Charity Commission published new sanctions guidance for charities operating in the Middle East and their trustees.  The guidance does not introduce new requirements for charities, but does draw together existing guidance from across government to assist charities in assessing and managing the risks they face when delivering life-saving work. (https://www.gov.uk/guidance/charities-operating-in-the-middle-east-guidance-and-support-for-trustees)