UK Weekly Sanctions Update - Week of January 19, 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 Sanctions

• UK Government imposes penalty on Bank of Scotland for breach of financial sanctions: On 26 January 2026, OFSI published a notice regarding a penalty of £160,000 imposed on the Bank of Scotland for breaches under the Russia regime. Between 8 February and 24 February 2023, the Bank of Scotland processed 24 payments, totalling £77,383.39, to or from a personal current account held by a sanctioned individual. OFSI concluded that the processing of these 24 payments breached regulation 11 (dealing with funds) and regulation 12 (making funds available) of the Russia (Sanctions) (EU Exit) Regulations 2019. (https://assets.publishing.service.gov.uk/media/697741f167ae94b3280137ee/Penalty_Publication_Notice_LBG_2026.pdf).
• Migita v JP Morgan – UK Court holds that EU Reg prevented JP Morgan from onboarding Russian nationals: On 21 January 2026, the Central London County Court rejected a claim under the Equality Act 2010 brought by three Russian nationals against JP Morgan SE, a German subsidiary of JP Morgan Chase with a London branch. The claim was brought against JP Morgan SE after the bank refused to onboard the three individuals as clients for investments exceeding €100,000. The claimants alleged nationality-based discrimination, but the Court held that the bank's refusal was justified by Article 5(b)(1) of Regulation (EU) No. 833/2014, which prohibits EU entities from accepting deposits over €100,000 from Russian nationals. (https://www.mayerbrown.com//-/media/files/uploads/migita-v-jp-morgan.pdf?rev=8802dbdf79a04c59acc53e3bc87d1c78).

Iran Sanctions

• UK parliament library publishes Iran protests sanctions briefing: On 20 January 2026, the UK Government published a research briefing on the response to the January 2026 protests in Iran, outlining the UK's current sanctions policy, including applying recent asset freeze measures to 286 individuals and 260 organisations under the UK’s Iran and Iran (Nuclear) sanctions regimes. (https://commonslibrary.parliament.uk/research-briefings/cbp-10462/).