UK Weekly Sanctions Update - Week of November 24, 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

• OFSI amends General Licence for transactions related to agricultural commodities under the Russia Regulations: On November 28, 2025, OFSI amended General Licence INT/2022/2349952, which authorises certain exporters and trade licence holders to receive or transfer funds or economic resources in connection with the export, sale, production and transport of agricultural commodities, subject to certain terms and conditions. The amendments to the General Licence reflect changes to Schedule 3E Part 2A of the Russia Regulations, expending the definition of fertiliser to include those permitted under commodity code 2814 and its subheadings. (28.11.2025_INT-2023-2349952_GL.pdf).
• UK Government updates one entry on the UK Sanctions list under the Russia regime: On November 28, 2025, the UK Government amended the entry for Sergey Vladimirovich Mikhailov under the Russia regime, This individual remains subject to an asset freeze. (Notice_Russia_281125.pdf).
• OFSI issues General Licence for the Continuation of Business of Lukoil International Entities and publishes related FAQ: On November 27, 2025, OFSI issued General Licence INT/2025/8031092 under the Russia regime.  This General Licence authorises UK persons to continue business operations involving Lukoil International GmbH and its subsidiaries, including payments and the provision and receipt of economic resources, subject to certain terms and conditions. The General Licence expires on February 26, 2026.  OFSI also published FAQ 174, which states that any renewal of this General Licence would be considered in the context of the ongoing negotiations on the sale of PJSC Lukoil’s international assets. (General_Licence_-_Continuation_of_Business_Lukoil_International.pdf; https://www.gov.uk/government/publications/uk-financial-sanctions-faqs/uk-financial-sanctions-faqs).
• UK Court rejects application anti-suit due to risk of breaching EU sanctions: On November 25, 2025, the UK Commercial Court handed down its judgment in FH Holding Moscow Ltd v AO UniCredit (Russia) and UniCredit SPA (Italy) [2025] EWHC 3111 (Comm).  FH Holdings, which operate in Russia, had borrowed funds from UniCredit, an Italian bank, in 2018 under a facility agreement governed by English law which referred disputes to arbitration in Vienna. FH Holdings provided Russian property as security for the loan under a separate agreement with UniCredit AO, which referred disputes to the Russian courts.  In March 2025, Unicredit AO filed a claim in Moscow seeking foreclosure of FH Holdings’ mortgaged Russian assets.  FH Holdings applied to the UK Courts for an anti-suit injunction to restrain the Russian proceedings.  The Court rejected the application stating that the risk the Russian courts would compel, FH Holdings to breach EU sanctions was too remote to justify interference with he Russian proceedings, and that (ii) UK public policy of supporting EU Russia sanctions cannot create sufficient interest for the UK court to issue an anti-suit injunction where there are no other links to English jurisdiction.  (FH Holding Moscow Ltd v AO Unicredit Bank & Anor [2025] EWHC 3111 (Comm) (25 November 2025)).
• NCA exposes billion-dollar money laundering network that purchased bank to fund Russian war effort: On November, 21, 2025, the UK’s National Crime Agency (“NCA”) issued a press release with updated information on Operation Destabilise, an international probe into a billion dollar money-laundering network active in the United Kingdom that reportedly purchased a Kyrgyzstan bank to facilitate sanctions evasion and payments in support of Russian military efforts. According to the press release, the NCA has supported its international law enforcement partners in seizing $24 million and over EUR 2.6 million from the network, in addition to 128 arrests and the seizure of more than £25 million in cash and cryptocurrency in the United Kingdom alone. (Operation Destabilise: NCA exposes billion-dollar money laundering network that purchased bank to fund Russian war effort - National Crime Agency).

Iran sanctions

• UK court holds that US sanctions have effect of suspending UK contract payment obligation: On November 24, 2025, the UK Commercial Court handed down its judgment in Beneathco v RJ O’Brien Ltd [2025] EWHC 3079 (Comm).  Beneathco, a UAE entity, held a cash balance of around USD 16.5 million in a derivatives trading account with RJ O’Brien Ltd (RJOL), an FCA-regulated broker, in 2020 when it was designated as a US sanctions target under the US Iran sanctions programme. The claimant amended an initial payment instruction to ask RJOL to make payment to a nominated account in the name of a third party.  The Court dismissed the claim and held that RJOL was under no payment obligation because (i) the claimant had not made a valid demand - payment could only be made in USD, and its request for payment in AED was ineffective; and (ii) RJOL was entitled to rely on the Ralli Bros defence since payment in USD would have involved an act within the United States in breach of US sanctions. (Beneathco DMCC v R.J. O'Brien Ltd [2025] EWHC 3079 (Comm) (24 November 2025)).

Cyber financial sanctions

• UK Government amends one entry on the UK sanctions list under the Cyber regime: On November 24, 2025, the UK Government amended the entry for Andrei Valerevich Kozlov on the UK sanctions list under the cyber regime. This individual remains subject to an asset freeze. (Notice_Cyber_DDMMYY.docx).

Other sanctions

• Solicitors Regulation Authority publishes notice on compliance with UK sanctions, and plans to send tailored guidance to 490 firms: On November 11, 2025, the UK’s Solicitors Regulation Authority (“SRA“) issued a notice on compliance with UK sanctions following an analysis of data gathered through its latest anti-money laundering data collection exercise. Among other things, the SRA stated that it plans (i) to send tailored guidance letters to 490 firms where data suggests that sanctions controls could be strengthened; and (ii) to conduct desk‑based reviews to understand sanctions risks and exposure with firms that face a heightened sanctions risk (e.g. due to clients with connections to sanctioned countries). The notice encourages firms to ensure that their sanctions controls are proportionate and kept under regular review. (SRA | Next steps to follow after sanctions exercise | Solicitors Regulation Authority).