UK Weekly Sanctions Update - Week of May 5, 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 adds more than 110 entries (including 100 ships) to the UK sanctions list under the Russia regime, targeting Russia’s “shadow fleet”: On May 9, 2025, the UK Government proscribed 101 ships and added five individuals and four entities to the UK sanctions list under the Russia regime.  The new measures target Sogalsie Insurance Company Limited, Romarine AS, BX Energy and Nord Axis Ltd, among others.  In a press release, the UK Government described the new measures as the “largest ever sanctions package” targeting Russia’s shadow fleet in an effort to increase pressure on Russia and protect UK and European critical national infrastructure. (https://assets.publishing.service.gov.uk/media/681d97c79ef97b58cce3e615/Notice_Russia_090525.pdf; Prime Minister to announce largest ever sanctions package targeting shadow fleet as UK ramps up pressure on Russia - GOV.UK; https://www.gov.uk/government/news/uk-and-international-partners-confirm-support-for-special-tribunal-on-crime-of-aggression-as-foreign-secretary-visits-lviv).
• OFSI issues first information enforcement penalty on Svarog Shipping Company for failure to respond to RFI under Russia regime: On May 9, 2025, the UK Office of Financial Sanctions Implementation (OFSI) announced a £5,000 monetary penalty against Svarog Shipping Company Limited for a failure to comply with its information obligations under the Russia regime. In its penalty notice, OFSI identified various aggravating factors, including that: Svarog neglected or failed to take reasonable care to comply with its information obligations, notwithstanding its receipt of several communications from OFSI, and Svarog ought to have been more vigilant to OFSI’s request given it operates in a sector with elevated exposure to sanctions risks. (https://assets.publishing.service.gov.uk/media/681c69ff3f1c73824ee3e56e/Publication_Notice_-_Svarog.pdf).

Other Sanctions

• UK Government publishes notice to exporters noting the exclusion of certain nuclear equipment from 13 open general export licences: On May 9, 2025, the UK Government published Notice to Exporters NTE 2025/14, which noted updates to 13 Open General Export Licence (OGELs), namely to exclude certain nuclear-related equipment from the scope of those export licences. Naval nuclear propulsion equipment under ML9 has been removed from the scope of all of the OGELs in question; nuclear power generating equipment under ML17g has been excluded from eight of the OGELs. (https://www.gov.uk/government/publications/notice-to-exporters-202514-changes-to-scope-on-13-open-general-licences/nte-202514-changes-to-scope-on-13-open-general-licences).
• OFSI publishes blog on compliance lessons for industry in relation to information offences: On May 8, 2025, OFSI published a blog post titled “Svarog Penalty: A Lesson in Information Offences.”  The blog post identifies key compliance lessons for industry in light of the publication of its first information offence enforcement action announced against Svarog on the same day. In particular, OFSI states that companies should: recognise the seriousness of failing to respond promptly to RFIs; engage proactively and candidly with OFSI when it comes to RFIs; have effective communication and monitoring systems in place; and consider other compliance and reporting obligations. (https://ofsi.blog.gov.uk/2025/05/08/svarog-penalty-a-lesson-in-information-offences/).
• UK Solicitors Regulation Authority updates sanctions guidance: On May 1, 2025, the UK Solicitors Regulation Authority (SRA) updated its guidance for legal professionals on compliance with UK financial sanctions. Updates to the guidance include the addition of a new case study to illustrate how firms may inadvertently face sanctions risk, the addition of new red flags relating to sanctions circumvention risk, and clarification on reporting requirements and licensing. (https://www.sra.org.uk/solicitors/guidance/financial-sanctions-regime/).