UK Weekly Sanctions Update - Week of May 12, 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 Parliament approves Russia (Sanctions) (EU Exit) (Amendment) Regulations 2025: On May 14, 2025, the UK Parliament approved the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2025, which were laid before Parliament on 23 and 24 April 2025 and which impose further trade sanctions on Russia, including certain dealings in further categories of chemicals, plastics, metals, machinery and electronics, technological information and synthetic diamonds. (Russia (Sanctions) (EU Exit) (Amendment) Regulations 2 - Hansard - UK Parliament; 24th Report from the Secondary Legislation Scrutiny Committee; https://www.legislation.gov.uk/uksi/2025/504/contents/made).
• OFSI extends General Licence relating to Amsterdam Trade Bank to May 2030: On May 12, 2025, OFSI amended General Licence INT/2022/1678476, which authorises Amsterdam Trade Bank N.V (“ATB”) to make or receive certain payments in connection with inter alia the winding down of transactions with ATB and ATB’s insolvency proceedings, subject to certain terms and conditions.The amendments permit the bankruptcy trustees of Amsterdam Trade Bank N.V to fulfil their statutory functions as bankruptcy trustees, and extends the expiry date of the general licence to 12 May 2030. (12.05.2022_Amsterdam_Trade_Bank_N.V_wind_down_-_basic_needs_-_insolvency_payments_-_PN_INT-2022-1678476__Final___002_.pdf; https://assets.publishing.service.gov.uk/media/6821e9aaf16c0654b19060f1/INT.2022.1678476_Amsterdam_Trade_Bank_N.V_-_winding_down_-_basic_needs_-_insolvency_GL__Final___002_.pdf).

Iran Sanctions

• UK High Court refuses security for costs application where sanctioned party’s frozen funds are already held by the defendant in claim affected by the impact of US sanctions: On May 14, 2025, judgment was handed down in a security for costs application in Virgo Marine and Nixie Marine Inc v Reed Smith LLP, Reed Smith LLP v Barclays Bank Plc [2025] EWHC 1157 (Comm).  Virgo and Nixie Marine previously paid $13 million to Reed Smith, as escrow agent, in relation to the purchase of an oil tanker.  Prior to completion of the sale, Virgo was designated as a US SDN.  Reed Smith instructed its bank, Barclays, to freeze the funds.  Reed Smith later concluded that it was not subject to US sanctions, and instructed Barclays to return the funds to Virgo and Nixie; however, Barclays has refused to do so.  Reed Smith applied for security for costs to cover both its and Barclays’ costs to trial.  Foxton J refused the application, concluding that it would not be just in all the circumstances. (https://www.bailii.org/cgi-bin/format.cgi?doc=/ew/cases/EWHC/Comm/2025/1157.html).

Syria Sanctions

• UK Parliamentary Committee debates Syria (Sanctions) (EU Exit) (Amendment) Regulations 2025: On May 13, 2025, the Delegated Legislation Committee debated the Syria (Sanctions) (EU Exit) (Amendment) Regulations 2025 which revoked certain UK sanctions measures on some sectors of the Syrian economy, including transport, trade, energy and finance. (Syria (Sanctions) (EU Exit) (Amendment) Regulations 20 - Hansard - UK Parliament; https://www.legislation.gov.uk/uksi/2025/507/contents/made).

Other Sanctions

• ECJU publishes Notice to Exporters announcing the launch of F680 approval through its new system: On May 16, 2025, the ECJU published Notice to Exporters NTE 2025/15: F680 giving notice of the launching the MOD security approval form 680 (F680) as the latest product on the 'apply to export controlled goods' service (previously known as LITE). This update enables F680 applications to be processed through the new system, allowing F680 applications to move away from SPIRE. ECJU plans to migrate all F680 applications from SPIRE to the new platform in the coming weeks. (NTE 2025/15: F680 - GOV.UK).
• ECJU publishes strategic export controls commentary for 2024: On May 15, 2025, the ECJU published statistics on strategic export control licensing for 1 October to 31 December 2024, and for 2024 as a whole. In Q4/2024, 94% (2,113) of licensing decisions led to licences being issued; 6% (146) were refused; and none were revoked. During 2024, 95% (10.815) of licensing decisions led to licences being issued; 5% (600 were refused; and none were revoked.  The highest number of SIELs were issued for exports to China (808), the USA (756) and India (580).  The most valuable destinations to which goods were shipped under SIELs were South Korea (£56.3 bn), China (£53.2 bn) and India (£10.6 bn). (https://www.gov.uk/government/statistics/strategic-export-controls-licensing-statistics-1-october-to-31-december-2024/strategic-export-controls-commentary-1-october-to-31-december-2024).
• UK government publishes review of sanctions implementation and enforcement: On May 15, 2025, the UK government published a cross-government review of sanctions implementation and enforcement. The review was launched by the Minister for Europe in October 2024 to consider ways to strengthen the UK’s enforcement model. The aims of the review were to identify further steps to improve and facilitate compliance, increase the deterrent effect of enforcement, and invigorate the cross-Government toolkit. Amongst other things, the identified actions following the review include; the creation of additional guidance for sectors less familiar with sanctions compliance; the consolidation of the UK Sanctions List and the Consolidated List of asset freeze targets into a single sanctions list for all UK designations; the development of an accelerated civil penalty process and early settlement scheme for certain financial sanctions breaches for public consultation; and regular publication of sanctions enforcement action and disruptions. (Cross-government review of sanctions implementation and enforcement - GOV.UK).
• New reporting obligations on high value dealers, art market participants, letting agents and insolvency practitioners come into effect: On May 14, 2025, the list of ‘relevant firms’ subject to financial sanctions reporting requirements was expanded to include high value dealers, art market participants, letting agents and insolvency practitioners. These changes were laid before Parliament in November 2024 under the Sanctions (EU Exit) (Miscellaneous Amendments) (No. 2) Regulations 2024.  The OFSI has published a reminder of the guidance it has produced to support these industries to navigate their reporting requirements. (Financial sanctions guidance for High Value Dealers & Art Market Participants - GOV.UK; Financial sanctions guidance for letting agents - GOV.UK; Financial sanctions guidance for Insolvency Practitioners - GOV.UK; UK Financial Sanctions FAQs – namely FAQs 132 to 144).
• UK government faces judicial review over export of fighter jet components to Israel: On May 13, 2025, human rights organisation Al-Haq commenced a judicial review against the UK Government over its policy on licensing arms exports to Israel for use in Gaza.  Last year, the UK’s Department for Business and Trade exempted F-35 parts from the suspension of certain arms export licenses for exports to Israel. (UK export of F-35 parts to Israel unlawful, Palestinian NGO tells court | Reuters; https://www.theguardian.com/world/2025/may/13/no-evidence-of-genocide-in-gaza-uk-lawyers-say-in-arms-export-case).