UK Weekly Sanctions Update - Weeks of July 13 and 20, 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.

• OFSI publishes FAQ guidance on basic needs allowance licences: On 21 July 2026, OFSI published six new FAQs (197–202) on basic needs allowance licences, which is a type of specific licence the can be issued under the basic needs licensing ground across all non-counter-terrorism sanctions regimes. (OFSI Financial Sanctions FAQs).
• Updates to UK Sanctions List: various updates were made to the UK Sanctions List including (inter alia): on 13 July 2026, the FCDO added the Islamic Movement of Companions of the Right to the UK Sanctions List under the Iran (Sanctions) Regulations 2023. (Sanctions Notice); and also on 13 July, the UK and the EU imposed a joint cyber sanctions package on Russia, with 24 individuals and entities being added to the UK Sanctions Lists. (UK and EU strike Russian cyber networks with new sanctions - GOV.UK; Sanctions Notice; Sanctions Notice).
• OFSI amends arbitration costs General Licence INT/2025/5787748: On 16 July 2026, OFSI amended the reporting requirements under General Licence INT/2025/5787748 which permits payments to arbitration associations and arbitrators to cover fees and expenses that would otherwise be prohibited under the UK’s Russia and Belarus sanctions regulations. (Arbitration_Costs_GL_INT-2025-5787748_16_July_2026.pdf).
• OFSI extends General Licence INT/2025/6641960: On 13 July 2026, OFSI extended until 16 July 2027 General Licence INT/2025/6641960 under the Russia and Belarus Regulations which allows non-designated persons who have made investments through designated brokers to transfer their funds to a non-designated broker. (Brokerage_General_Licence_INT_2025_6641960.pdf).
• R v Hauser & Wirth Gallery Ltd – UK Court provides guidance on "making available" and "ordinarily resident": In R v Hauser & Wirth Gallery Ltd & Anor [2026] EWCR 7, the Crown Court dismissed charges brought under the regulation 46B(2) Russia (Sanctions) (EU Exit) Regulations 2019 (the "Regulations") against an art gallery, Hauser & Wirth Gallery Ltd ("H&W"), and a fine art logistics company, Artay Rauchwerger Solomons Ltd (“ARS”), for the sale of artwork (a luxury good for the purposes of the Regulations) to Alexander Popov ("Mr Popov"). The Court considered whether the artwork had been “made available” to Popov and whether he was a “person connected with Russia” and in particular whether he was “ordinarily resident” in Russia. The Court held that the artwork was “made available” because of the combination of transfer of legal title to Popov, payment by Popov and release into the control of parties acting on Popov’s instructions. Notably the Court also held that mere entitlement or transfer of legal title was not sufficient for "making available". The Court held that “ordinary residence” is a question of fact and degree and “requires evidence that Russia remained part of the settled and regular order of the person’s life at the material time”. On the facts of the case, the Court held that Popov was not ordinarily resident in Russia at the relevant time. (2026 07 09 - HAUSER & WIRTH GALLERY LTD & Anor - APPROVED Judgment).