UK Weekly Sanctions Update - Week of September 29, 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.

Iran sanctions

• UK Government amends one entry on the UK sanctions list under the Iran (Nuclear) regime: On October 3, 2025, the UK Government amended the entry for Europaisch-Iranische Handelsbank AG. This entity remains subject to an asset freeze. (https://assets.publishing.service.gov.uk/media/68df91868c1db6022d0ca092/Notice_Iran__Nuclear__031025.pdf).
• UK Government reimposes 121 designations on the UK sanctions list under the Iran (Nuclear) regime: On October 1, 2025, the UK Government reimposed 121 UN sanctions designations following the end of the snapback process. 78 of these entries were listed by the UK before this date and have had changes made to note that they are subject to additional UN sanctions on top of the existing autonomous designations. (Notice_Iran__Nuclear__011025.pdf).
• OFSI issues General Licence relating to the wind-down of transactions involving certain Iranian Banks: On September 29, 2025, OFSI issued General Licence INT/2025/7345464 under the Iran regime, which authorises the wind down of any transactions involving a party listed in Annex 1 of the licence, including Bank Melli and Bank Tejarat, subject to certain terms and conditions.  The general licence expires on November 12, 2025. (General_Licence_-_UK_Iranian_Banks.pdf).
• OFSI issues General Licence relating to the wind-down of transactions involving certain Iranian Banks (Worldwide): On September 29, 2025, OFSI issued General Licence INT/2025/7345664 under the Iran regime, which authorises the wind down of any transactions involving a party listed in Annex 1 of the licence, including Bank Mellat and the First Islamic investment Bank, subject to certain terms and conditions. The general licence expires on October 28, 2025. (General_Licence__-_Worldwide_Banks.pdf).
• OFSI issues General Licence relating to the wind-down of transactions involving UK-based firms: On September 29, 2025, OFSI issued General Licence INT/2025/7345264 under the Iran regime, which authorises the wind down of any transactions involving Iran Insurance Company, NIOC International Affairs Ltd or any of their subsidiaries, subject to certain terms and conditions.  The general licence expires on October 28, 2025. (General_Licence_-_UK_Entities.pdf).
• OFSI issues General Licence relating to Shah Deniz Project Activities: On September 29, 2025, OFSI issued General Licence INT/2025/7363752 under the Iran regime, which authorises certain persons to undertake any activity necessary for the continued operation of the Shah Deniz Project, subject to certain conditions, including that no funds or economic resources are made available to a designated person. (General_Licence_-_Shah_Deniz_Project_Activities.pdf).
• UK Government adds 71 entries to the UK sanctions list under the Iran regime: On September 29, 2025, the UK Government designated 62 entities and 9 individuals under the Iran Nuclear Sanctions Regime. These measures follow the imposition of the snapback mechanism that was triggered by France, Germany and the United Kingdom on August 28, 2025. (Notice_Iran__Nuclear__290925.pdf; https://www.gov.uk/government/news/e3-joint-statement-on-iran-activation-of-the-snapback).
• OFSI adds new FAQ relating to licenses granted under the UN regime prior to 2015: On September 29, 2025, OFSI published FAQ 168, which stated that all specific licences issued by HMT under the UN regime prior to 2015 ceased to have effect upon the designated person being delisted. Consequently, a party would have to apply to OFSI for a specific licence in respect of any activities that may be caught by financial sanctions targeting a re-designated person. (UK Financial Sanctions FAQs - GOV.UK)

Counter-terrorism (Domestic) sanctions

• UK Government amends two entries on the UK sanctions list under the Counter-Terrorism (Domestic) regime: On October 3, 2025, the UK Government amended the entries for Embers of an Empire and Rampage Productions. The entries remain subject to an asset freeze. (Notice_Counter_Terrorism__Domestic__031025.pdf).

Russia sanctions

• OFSI issues £152,750 monetary penalty to pharmaceutical company for breach of financial sanctions under the Russia regime: On September 30, 2025, OFSI issued a £152,750 monetary penalty to Colorcon Limited for making funds available to UK designated persons in breach of UK financial sanctions relating to Russia. In particular, between 23 March and 2 December 2022, the company made 79 payments worth £128,277.72 to non-designated employees and service providers with accounts held at certain sanctioned Russian banks in violation of UK sanctions.  In its penalty notice, OFSI stated in its compliance lessons for industry, among other things, that it is insufficient for companies to rely on third parties to conduct sanctions screening on their behalf, sanctions policies and processes should be regularly reassessed to maximise effectiveness in response to the changing geopolitical landscape, and breaches should be disclosed to OFSI as soon as reasonably practicable after discovery. (https://assets.publishing.service.gov.uk/media/68db9df2ef1c2f72bc1e4bf0/Colorcon_Penalty_Notice.pdf).

Other sanctions

• UK Government updates AUKUS Open General Licence: On October 2, 2025, ECJU published a notice to exporters noting certain updates to the AUKUS Open General Licence, including updated text on Authorised User Community and clarification on F680 requirements.  (https://assets.publishing.service.gov.uk/media/68dbd2ab49e17d00a56ffc1b/open-general-licence-aukus-nations.pdf; https://www.gov.uk/government/publications/notice-to-exporters-202526-update-to-open-general-export-licence/nte-202526-update-to-open-general-export-licence).
• OFSI publishes reminder about enforcement consultation: On 22 July, OFSI launched a consultation to seek views on proposed changes to its enforcement policies and processes.  On October 1, 2025, OFSI published a reminder that the deadline to submit a response to the consultation is 13 October 2025.  (https://www.gov.uk/government/consultations/improving-civil-enforcement-processes-for-financial-sanctions).