UK Weekly Sanctions Update - Weeks of August 24, and August 31, 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.

• NCA, OFSI and the FCDO issue alert on the A7 sanctions evasion network: On 31 August 2026, the NCA and its National Economic Crime Centre, in conjunction with OFSI and the FCDO, issued an alert on the A7 sanctions evasion mechanism. A7 is a complex web of financial structures and tools hosted between Kyrgyzstan and Russia, with state-level backing. This alert highlights the risks posed to the international financial system and key concerns to consider regarding existing anti-money laundering controls. (https://www.nationalcrimeagency.gov.uk/who-we-are/publications/826-necc-a7-sanctions-evasion-mechanism/file)
• OFSI imposes penalty for Russia sanctions breaches: On 11 August 2026, OFSI imposed a penalty of £4,732,830.58 on Citibank, N.A., London Branch. The penalty was published on 2 September 2026, and was imposed for breaches of the Russia (Sanctions) (EU Exit) Regulations 2019 and the Global Anti-Corruption Sanctions Regulations 2021. (CBNA_London_Public_Penalty_Notice.pdf).
• ECJU publishes strategic export controls licensing statistics: On 27 August 2026, the ECJU published the Q1 2026 data for licensing decisions for standard individual export licences, which are up by 11% from the previous quarter (Q4 2025). (Strategic export controls commentary: 1 January to 31 March 2026 - GOV.UK)
• NCA settles with company linked to suspected money laundering and sanctions evasion: On 27 August 2026, the National Crime Agency ("NCA") entered into a settlement agreement with ENEX Premium Trading Limited (“ENEX”), an agricultural trading company owned by Azerbaijani national Nadir Valiyev. The NCA investigation revealed that funds frozen in UK accounts were traced to Chinese bank accounts that had received tens of millions of pounds from suspected front companies, some of which have since been designated under US sanctions for facilitating illicit Iranian oil sales and funnelling money to the Iranian QODS Force. The funds were also linked to allegations that Mr Valiyev's companies had been involved in the shipment of stolen Ukrainian grain. Mr Valiyev denied any criminal activity, and the settlement does not constitute an admission of unlawful conduct. (NCA Press Release)
• OTSI publishes Annual Review for 2025-26: On 27 August 2026, the Office of Trade Sanctions Implementation ("OTSI") published its Annual Review for 2025-26. In the reporting period, OTSI received 178 reports or referrals relating to potential breaches of trade sanctions. The majority of reports were submitted by the financial services sector and related to potential breaches under the UK Russia regime. 104 enforcement cases were closed, with 41 for which no breach was identified and 40 cases which were closed by OTSI and referred to HMRC for a range of reasons, including criminal enforcement consideration or where potential breaches predate OTSI’s enforcement powers. (OTSI Annual Review 2025-26 – GOV.UK)
• TikTok submits voluntary disclosure report to OFSI: On 21 August 2026, TikTok disclosed that the company submitted a voluntary disclosure to OFSI and the Central Bank of Ireland in April 2026, having identified a potential issue relating to its compliance with applicable sanctions regulations. TikTok has reportedly made disclosures to other regulators on a preliminary basis. As the matter remains under review, the nature of the suspected breach has not been publicly disclosed. (MLex)