UK Weekly Sanctions Update - Weeks of March 23, and March 30, 2026

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

• OFSI imposes financial penalty for breach of Russia (Sanctions) (EU Exit) Regulations 2019: On 19 March 2026, OFSI imposed a £390,000 penalty on Apple Distribution International Limited (“ADI”), an Irish-incorporated entity, for breaches of the Russia (Sanctions) (EU Exit) Regulations 2019. ADI instructed a UK bank to make two payments totalling £635,618.75 in June and July 2022  to Okko LLC, which was owned by JSC New Opportunities, a designated person. This is the first time OFSI has imposed a penalty on a non-UK company for taking action in the UK, and the first use of OFSI’s new settlement mechanism. (ADI_Public_Penalty_Notice.pdf)
• UK Supreme Court hands down judgement in Celestial Aviation case: In UniCredit Bank GmbH, London Branch (Respondent) v Celestial Aviation Services Ltd (Appellant) [2026] UKSC 10, the Supreme Court determined that Regulation 28(3) of the Russia (Sanctions) (EU Exit) Regulations 2019 prohibited payment by UniCredit (a German bank) under letters of credit (“LCs”) issued by Sberbank in respect of leases of aircraft to Russian airlines entered into before the imposition of the prohibition. The Court also held (obiter) that UniCredit would have had a defence under section 44 of the Sanctions and Anti-Money Laundering Act 2018, which provides protection for acts done in the reasonable belief that the act is in compliance with sanctions. (UniCredit Bank GmbH, London Branch (Respondent) v Constitution Aircraft Leasing (Ireland) 3 Ltd and another (Appellants); UniCredit Bank GmbH, London Branch (Respondent) v Celestial Aviation Services Ltd (Appellant))
• UK Prime Minister's Office issues press release on shadow fleet vessels in UK waters: On 25 March 2026, the UK Government issued a press release stating that British military forces will be able to board shadow fleet vessels transiting UK waters. (Shadow fleet set to be interdicted in UK waters in latest blow to Russia - GOV.UK)

Other

• OFSI publishes Annual Review 2024-2025: On 2 April 2026, OFSI published its Annual Review 2024-2025. Highlights include: (a) £37 billion worth of assets were reported as frozen to OFSI, a significant increase from £24.4 billion in the previous financial year; (b) OFSI issued 19 general licences and processed 904 specific licensing decisions; (c) there were 57 enforcement actions, with financial services and legal sectors most affected (https://assets.publishing.service.gov.uk/media/69ce735f826d774e7b263dcc/OFSI_Annual_Review_2024-25.pdf)
• UK Government adds summaries for each sanctions regime: On 25 March 2026, the UK Government updated each sanctions regime’s statutory guidance to include a summary of inter alia the respective regime’s purpose, scope and prohibitions. (Current UK sanctions regimes - GOV.UK)
• OFSI issues guidance on compliance with sanctions: On 23 March 2026, OFSI issued guidance on use exceptions and licences under UK sanctions. (How to use exceptions and licences to comply with sanctions  - GOV.UK)
• OFSI Director publishes blog post on OFSI’s 10^th anniversary: On 1 April 2026, the Director of OFSI, Giles Thomson, commemorated OFSI’s tenth anniversary with a blog post. (https://ofsi.blog.gov.uk/2026/03/31/ofsis-10-year-anniversary-reflections-from-giles-thomson-director-of-ofsi)