UK Weekly Sanctions Update - Week of October 13, 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 extends General trade licence Russia sanctions – sectoral software and technology: On October 16, 2025, the Export Control Joint Unit (ECJU) extended the validity of General trade licence Russia sanctions – sectoral software and technology, which authorises inter alia the transfer of business enterprise software and technology that is otherwise prohibited by Chapter 4N of the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2025. The expiration of the general licence has been extended from October 20, 2025 to April 17, 2026. (NTE 2025/27: general trade licence Russia sanctions – sectoral software and technology - GOV.UK; General trade licence Russia sanctions – sectoral software and technology - GOV.UK).
• UK Government amends one entry on the UK Sanctions list under the Russia regime: On October 16, 2025, the UK Government amended the entry for German Valentinovich Belous on the UK sanctions list under the Russia regime. This individual is still subject to an asset freeze. (https://assets.publishing.service.gov.uk/media/68f0f4531c9076042263ef72/Notice_Russia_161025.pdf).
• UK Government adds 39 entries to UK Sanctions List and specifies 51 ships under the Russia regime: On October 15, 2025, the UK Government added 24 entities, including Rosneft, Lukoil and Nayara Energy Limited, and 5 individuals to the UK sanctions list and specified 51 ships under the Russia regime.  According to the UK Government, these measures represent the UK’s “strongest sanctions yet on Russia, choking off energy revenues that flow into its war chest by directly targeting oil giants Rosneft and Lukoil.” (Notice_Russia_151025.pdf; https://www.gov.uk/government/news/huge-blow-for-putins-war-machine-as-uk-sanctions-russian-oil).
• OFSI amends Russian Oil Exempt Projects General Licence: On October 15, 2025, OFSI amended General Licence INT/2025/5635700, which authorises the continuation of business operations with certain parties to the extent they are in relation to certain oil projects.  The scope of ‘relevant subsidiaries’ to which the general licence relates was expanded to include Lukoil, Rosneft and any entity they respectively own or control; the list of exempt projects was expanded to include inter alia Shah Deniz, the Caspian Pipeline Consortium and the Azerbaijan Gas Supply Company.  The exemption for these oil exempt projects expires on October 14, 2027. (OFSI General licence INT/2025/5635700).
• OFSI issues General Licence relating to the wind-down of transactions involving certain energy entities: On October 15, 2025, OFSI issued General Licence INT/2025/7538856, which authorises the wind down of any transactions involving Nayara Energy Limited, National Pipeline Group Beihai Liquified Natural Gas Co Ltd, Shandong Yulong Petrochemical Company, Shandong Baogang International Port Co, Jingang Port Co, Shandong Haixing Port Co or any of their subsidiaries, subject to certain terms and conditions. The general licence expires on November 13, 2025. (OFSI General Licence INT/2025/7538856).
• OFSI issues General Licence relating to the wind-down of transactions involving Rosneft and Lukoil: On October 15, 2025, OFSI issued General Licence INT/2025/7539056, which authorises the wind down of any transactions involving PJSC Lukoil Oil Company, PJSC Rosneft Oil Company or any of their subsidiaries, subject to certain terms and conditions. The general licence expires on November 28, 2025. (OFSI General Licence INT/2025/7539056).
• OFSI amends General Licence relating to petrol station payments for UK nationals in Kyrgyzstan and Tajikistan: On October 15, 2025, OFSI amended General licence INT/2025/5886860, which authorises certain payments to be made by UK nationals to purchase petrol from certain designated parties in Kyrgyzstan or Tajikistan.  The list of designated persons to which this General Licence relates now includes PJSC Lukoil Oil Company and PJSC Rosneft Oil Company, as well as their subsidiaries. The General Licence expires on March 15, 2027. (OFSI General licence INT/2025/5886860).

ISIL (Da’esh) and Al-Qaida sanctions

• UK Government amends one entry on the UK Sanctions list under the ISIL (Da’esh) and Al-Qaida regime: On October 17, 2025, the UK Government amended the entry for Ahmad Hussain AL-SHARAA on the UK sanctions list under the ISIL (Da’esh) and Al-Qaida regime. This individual is still subject to an asset freeze. (Notice_ISIL__Da_esh__and_Al-Qaida_171025.pdf).

Global Migration sanctions

• UK Government extends Global Migration sanctions regulations to overseas territories: On October 16, 2025, the Global Irregular Migration and Trafficking in Persons Sanctions (Overseas Territories) Order 2025 came into force. The Order extends the application of the UK’s Global Irregular Migration and Trafficking in Persons Sanctions Regulations to British overseas territories. (https://www.legislation.gov.uk/uksi/2025/1092/made).

Global Human Rights sanctions

• UK Government adds 12 entries to the UK sanctions list under the Global Human Rights regime: On October 14, 2025, the UK Government added six entities and six individuals to the UK sanctions list under the Global Human Rights regime. According to the UK government, these measures targeted a network that operates illegal scam centres across Southeast Asia. (Notice_Global_Human_Rights_141025.pdf; https://www.gov.uk/government/news/uk-and-us-take-joint-action-to-disrupt-major-online-fraud-network).

Other sanctions

• OFSI publishes Annual Review 2024-25: On October 15, 2025, OFSI published its annual report for 2024/25. Among other things, the report stated that during the reporting period OFSI had (i) issued 57 enforcement actions, including two monetary penalties, three disclosures and 23 warning letters; (ii) processed 904 specific licensing decisions (52% were granted; 40% were withdrawn and 4% were refused); (iii) issued guidance to the market to facilitate compliance with UK sanctions, including 159 alerts and blogs, FAQs and targeted advisories, and guidance on new regulations.  The report also states that £37 billion work of assets have been reported to OFSI as frozen, a 52% increase on the prior year. (OFSI Annual Review 2024-25: Effective Sanctions).
• Legal Services General Licence to be updated: On October 15, 2025, OFSI announced that General Licence INT/2025/7323088 will be issued to replace the existing legal services general licence (INT/2025/6160920), with effect from October 28, 2025.  Among other things, the new General Licences will reset the fees and expenses caps for Parts A and B of the Legal Services General Licence for the six-month period from 29 October 2025 until the licence expires on 28 April 2026, and the General Licence will apply to all UK autonomous regimes, save for the two Counter Terrorism regimes.
• OTSI publishes blog post highlighting the role of good due diligence in preventing breaches of trade sanctions: On October 13, 2025, the Office of Trade Sanctions Implementation (OTSI) published a case study highlighting the role of good due diligence in preventing breaches of trade sanctions. The case study related to the receipt of a number of suspected breach reports from the UK branch of a multinational bank in connection with the trade of certain products from Russia to a third country.  Owing to trade sanctions concerns, the UK branch in question performed enhanced due diligence checks and did not process the payments, and so OTSI concluded that there had not been a breach of trade sanctions.  OTSI included 8 key takeaways for industry arising from this case study.
• UK announces move to a single list for sanctions designations: On October 13, 2025, OFSI announced that from January 28, 2026, the UK Sanctions List (UKSL) will be the only source to all UK sanctions designations. The move will consolidate the UK Sanctions List and the Consolidated List of Asset Freeze Targets into a single list. This is in response to industry feedback that a single list will remove duplication of effort and simplify checks of who is subject to UK sanctions. (Moving to a single list for UK sanctions designations, 28 January 2026 - GOV.UK).