UK Weekly Sanctions Update - Week of October 20, 2025

In this weekly update, we summarise the most notable updates in the UK sanctions world. If you have any questions in respect of any of the developments set out below, please do not hesitate to contact a member of our London Global and Government Trade team listed above.

Russia sanctions

• UK Government amends five entries on the UK Sanctions list under the Russia regime: On October 23, 2025, the UK Government updated the entries for Alexandr Shulgin, Namina Dadashova, Mihajlo Perenčević, Alisher Usmanov and USM Holdings Limited on the UK sanctions list under the Russia regime. (https://assets.publishing.service.gov.uk/media/68fa2393e200d653d8b63711/Notice_Russia_231025.pdf)
• OFSI issues General Licence relating to continuation of business of Rosneft’s German subsidiaries: On October 22, 2025, OFSI issued General Licence INT/2025/7598960, which authorises UK persons to continue business operations with certain named German subsidiaries of PJSC Rosneft Oil Company, subject to certain terms and conditions. The General Licence expires on October, 22, 2027. (https://assets.publishing.service.gov.uk/media/68f8794bb391b93d5aa39a38/INT.2025.7598960_.pdf)
• UK Government responds to written question relating to Chelsea FC: On October 23, 2025, Lucy Rigby MP responded to a written question raised to the Chancellor of the Exchequer in relation to whether the UK is working with the EU and G7 partners to release frozen Russia-linked assets and the proceeds from the sale of Chelsea Football Club.  The UK Government response noted that the Chancellor is actively working with EU and G7 partners to explore all viable legal avenues to make use of Russia’s sovereign assets for the benefit of Ukraine in line with international law and that the UK Government is seeking to ensure that the proceeds from the sale of Chelsea FC are directed towards humanitarian causes in Ukraine as swiftly as possible. (https://questions-statements.parliament.uk/written-questions/detail/2025-10-20/83699) 

Iran sanctions 

• OFSI issues Interim Necessities General Licence under the Iran regime: On October 23, 2025, OFSI issued General Licence INT/2025/7628424, which authorises certain designated persons to make certain payments to UK Employees and UK Directors and their pensions, relating to the provision of services by IT Providers or accountants in connection with certain operations in the UK, subject to certain terms and conditions. This General Licence expires on April 22, 2026. (https://assets.publishing.service.gov.uk/media/68fa4eae30c331c88be6f04a/General_Licence-_INT-2025-7628424_.pdf)

Global Migration sanctions

• UK Government adds 13 entries to the UK Sanctions list under the Global Migration regime: On October 22, 2025, the UK Government added 12 individuals and one entity to the UK sanctions list under the Global Irregular Migration and Trafficking in Persons regime. According to the UK Government, these measures target gangs exploiting illegal migration routes through the Western Balkans and the financiers and suppliers of small boat equipment. (https://assets.publishing.service.gov.uk/media/68f8b76625d7d8af156dc286/Notice_Global_Irregular_Migration
  _and_Trafficking_in_Persons_221025.pdf; https://www.gov.uk/government/news/uk-sanctions-gangs-and-illicit-finance-network-propping-up-people-smuggling-trade) 

Haiti sanctions

• UK Government adds 2 entries to the UK Sanctions list under the Haiti regime: On October 20, 2025, the UK Government added Dimitri Herard and Kempes Sanon to the UK sanctions list under the UN Haiti regime. (https://assets.publishing.service.gov.uk/media/68f5feb728f6872f1663f08c/Notice_Haiti_201025.pdf; https://press.un.org/en/2025/sc16195.doc.htm)

Other sanctions

• OFSI publishes new legal services general licence FAQs: On October 24, 2025, OFSI published FAQs 170 and 171 to address anticipated changes to General Licence INT/2025/7323088, which authorises payments to be made to, for or on behalf of a designated person in connection with the provision of legal services, subject to certain terms and conditions. Among other things, FAQ 170 states that General Licence INT/2025/7323088 resets the fees and expenses caps for Parts A and B for the six month period from October 29, 2025 until expiry of that general licence, and FAQ 171 states that the general licence permitted payments to be sent from abroad into the UK bank account of certain non-UK bank accounts, subject to the terms and conditions of the general licence. At the same time, OFSI withdrew FAQs 54 and 76. (https://www.gov.uk/government/publications/uk-financial-sanctions-faqs/uk-financial-sanctions-faqs).
• OFSI issues frozen assets reporting reminder – deadline November 30, 2025: On October 23, 2025, OFSI published a reminder that its annual frozen assets review requires parties to submit a report by November 30, 2025 providing details of all frozen funds or economic resources that are owned, held or controlled by a designated person as at COB September 30, 2025. (https://assets.publishing.service.gov.uk/media/68c2a7e58c6d992f23edd8a5/Financial_Sanctions_Notice__
  FAR__2025_110925.pdf)
• OFSI issues new Legal Services General Licence: On October 22, 2025, OFSI issued General Licence INT/2025/7323088, which authorises certain payments and related acts necessary to facilitate the provision of legal services to designated persons, across all UK Autonomous Sanctions Regulations, subject to certain terms and conditions. The General Licence takes effect on October 29, 2025 and expires on April 28, 2026. (https://assets.publishing.service.gov.uk/media/68f8da6f25d7d8af156dc2ab/INT.2025.7323088_GL.pdf)
• UK Government removes HTS from list of proscribed terrorist organisations: On October 21, 2025, the UK Government deproscribed Hay’at Tahrir al-Sham (HTS) to enable closer engagement with the new Syrian government.  According to the UK Government, this step is part of the UK’s response to the ‘significant developments’ in Syria since forces led by President Ahmed Al Sharaa toppled the Assad regime in December 2024. (https://www.gov.uk/government/news/uk-removes-hayat-tahrir-al-sham-from-terrorist-organisation-list)