UK Weekly Sanctions Update - Week of September 8, 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 Government adds 30 entries to the UK sanctions list and proscribes 70 ships under the Russia regime: On September 12, 2025, OFSI added 27 entities and three individuals to the UK sanctions list and proscribed 70 ships under the Russia sanctions regime. The new measures primarily target the Russian oil and defence sectors. (Notice_Russia_120925.pdf).
• UK Government removes Ilya Brodskiy from UK sanctions list under Russia regime: On September 11, 2025, the UK Government removed Ilya Brodskiy from the UK sanctions list under the Russia regime.  According to OFSI’s notice, this individual is a former member of the supervisory board of Sovcombank. (https://assets.publishing.service.gov.uk/media/68c2a416838e7712ea2bfe9b/Notice_Russia_110925.pdf).
• UK High Court finds that owners made reasonable decision in good faith not to perform sub-charter due to sanctions risk: The judgment in Ceto Shipping Corporation v Savory Shipping Inc. [2025] EWHC 2033 (Comm), which was handed down on July 31, 2025, has been made public.  Among other things, Savory and the ship manager (DelfI0 refused to performance a charter for the carriage of Iranian origin oil due to concerns that this would breach US sanctions with regard to Iran and concerns that the cargo may have been ultimate destined for Venezuela and that the charter had been set up with the involvement of a sanctioned individual.  The management agreement provided that “[Delfi] shall not be obliged to comply with the provisions of this Agreement if in [its] reasonable judgment… it will expose them or their… crew, registered owners, to any sanction… imposed by any State.”  The Court accepted evidence that the risk of Savory and Delfi, among others being designated as an SDN was ‘very high’ in this case.  The Court concluded that Savory was entitled to refuse to perform the charter and Delfi was not in breach by acting on this refusal. (https://caselaw.nationalarchives.gov.uk/ewhc/comm/2025/2033?query=ceto+shipping+corporation).

Global Irregular Migration regime

• OFSI updates three general licences to include the Global Irregular Migration and Trafficking in Persons regime:  On September 11, 2025, OFSI updated General licence INT/2024/4907888 (payments for visa application services), General licence INT/2024/4888228 (statutory audit fees) and General licence INT/2022/2009156 (permitted payments to UK insurance companies) to include the Global Irregular Migration regime.

Other Sanctions

• ECJU releases details of October export control and sanctions symposium: On September 12, 2025, the ECJU published details of an upcoming Export Control Seminar that is taking place in London on October 15, 2025, including how to register. (https://www.gov.uk/government/publications/export-control-training-bulletin/export-control-training).
• OFSI publishes frozen asset reporting reminder: On September 11, 2025, OFSI published a reminder that all persons that hold funds or economic resources owned, held or controlled by a designated person are required to submit a report to OFSI by Sunday November 30, 2025, detailing the value of such assets as of September 30, 2025. (https://www.gov.uk/government/publications/annual-frozen-asset-review-and-reporting-form).
• OFSI publishes Disclosure notice in latest enforcement action targeting a regulated financial institution: on September 8, 2025, OFSI issued a Disclosure Notice stating that Vanquis Bank Limited (VBL) had made funds available to a designated person in violation of UK financial sanctions.  The breach occurred despite OFSI providing a pre-notification to VBL that a suspected VBL customer was to be sanctioned the following day. (Disclosure notice: 08 September 2025 - GOV.UK).
• UK Government updates UK sanctions guidance for non-UK businesses: On September 8, 2025, the UK Government updated section 3.2 (who must comply with UK sanctions) of its UK sanctions guidance for non-UK businesses. (UK sanctions guidance for non-UK businesses - GOV.UK).
• ECJU updates end-user and stockist undertaking form guidance: On September 8, 2025, the ECJU updated its end-user and stockist undertaking form guidance. The undertaking must be completed by an end-user or stockist if a UK exporter is applying for a standard individual export licence (SIEL), a standard individual trade control licence (SITCL), or a licence to provide technical assistance. (End-user and stockist undertaking (EUSU) form guidance - GOV.UK).