UK Weekly Sanctions Update - Weeks of April 27 and May 4, 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.

• FCDO announces new sanctions on to curb Russian drones: On 5 May 2026, the FCDO announced in a press release that it would introduce new sanctions to curb the production of Russian drones. These sanctions are also intended to affect the networks exploiting migrants, with 35 people and entities added to the sanctions list under the Russia (Sanctions) (EU Exit) Regulations 2019 and the Global Irregular Migration and Trafficking in Persons Sanctions Regulations 2025. (UK cracks down on Russia’s exploitation of vulnerable migrants and deadly drone capability - GOV.UK)
• OWH v RTI & Rusal [2026] EWHC 1015 (Comm): On 1 May 2026, the High Court dismissed an application to set aside an order permitting enforcement of an arbitration award, holding that the public policy interest attaching to ancillary sanctions provisions (here, the s.44 compliance defence) was insufficient to refuse enforcement. The court noted that it has discretion to refuse to enforce an arbitration award on public policy grounds. It accepted that the sanctions regime engaged vital public interests and recognised the importance of the immunity provisions in section 44 in mitigating the harsh consequences on organisations caught between contractual compliance and sanctions compliance. However, it drew a distinction between primary sanctioning provisions (i.e. sanctions prohibitions) and ancillary ones, such as s.44. In its view, ancillary provisions do not necessarily attract the same public policy interest as primary sanctioning provisions. This is subsequent to the 6 May 2025 decision, when the English Commercial Court rejected Rusal's application to set aside an order enforcing an LCIA arbitration award of VTB's German subsidiary OWH. Rusal’s Jersey subsidiary (RTI) entered into a currency swap contract with OWH in 2019, but following the imposition of EU, UK and US sanctions on VTB in 2022, RTI refused to pay margin calls under the contract. Subsequently, OWH terminated the contract and obtained an LCIA award against RTI for breach of contract, seeking enforcement in England and Jersey and obtaining enforcement from the English High Court in 2025. (OWH SE iL v RTI Ltd & Anor [2026] EWHC 1015 (Comm) (01 May 2026)
• UK Government to introduce legislation to proscribe the IRGC: On 28 April 2026, the UK Prime Minister confirmed that the Government will introduce new legislation enabling the proscription of the Iran’s Revolutionary Guard Corps (“IRGC”) as a terrorist organisation, as the existing Terrorism Act 2000 does not permit the proscription of state-backed groups. The proposed legislation follows a review by the UK independent reviewer of terrorism legislation, Jonathan Hall KC, who recommended a "proscription-style tool" making it a criminal offence to invite support for or promote a designated group backed by a foreign state. The IRGC is already subject to UK sanctions including asset freezes, travel bans and director disqualification sanctions under the Iran (Sanctions) Regulations 2023. (Keir Starmer promises imminent laws to ban IRGC
• UK House of Commons Library publishes briefings on the US/Iran conflict: On 28 April 2026, the UK House of Commons Library published three research briefings covering: (i) the background to the US-Iran conflict and the UK's response, (ii) the reopening of the Strait of Hormuz, and (iii) the US-Iran ceasefire and nuclear talks in 2026. The briefings provide background to the conflict and highlight the UK’s response to the conflict and coordinating with other countries to explore measures, including imposing sanctions against Iran, if the Strait of Hormuz remains closed.  (Israel/US-Iran conflict 2026: Background and UK response - House of Commons Library; Israel/US-Iran conflict 2026: Reopening the Strait of Hormuz - House of Commons Library; US-Iran ceasefire and nuclear talks in 2026 - House of Commons Library)