UK Weekly Sanctions Update - Week of June 23, 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 Sakhalin 2 exemption under two General Licences: On 27 June, 2025, OFSI extended General Licence INT/2025/5635700, which authorises certain activities with Gazpromneft-Sakhalin LLC in relation to Sakhalin-2, and General Licence INT/2022/2470156, which permits the maritime transfer of Russian oil below a certain price cap, each subject to certain terms and conditions.  The Sakhalin-2 exemption in each general licence has been extended to June 28, 2026. (INT-2022-2470156_-_Exempt_Projects_and_Countries_GL_2025_Final.pdf; https://assets.publishing.service.gov.uk/media/685ea75161d68e6ee1a92b71/INT-2022-2470156_-_Oil_Price_Cap_General_Licence_Publication_Notice_2025_Final.pdf INT.2025.5635700_GL_2025_Final.pdf; https://assets.publishing.service.gov.uk/media/685ea2e9c2633bd820a92b5a/INT.2025.5635700_PN_2025_Final.pdf).
• UK government updates 16 entries on the UK sanctions list under the Russia regime: On 26 June, 2025, the UK updated16 entries on the UK sanctions list under the Russia regime. (Notice_Russia_260625.pdf).
• UK Solicitors Regulatory Authority “rebukes” law firm for failure to comply with OFSI licences: On 24 June, 2025, the SRA published a regulatory settlement agreement with Steptoe International (UK) LLP for failing to comply with certain conditions of two OFSI licences. According to the agreement, the law firm was formally ‘rebuked’ and was ordered to pay £600 in relation to the costs of the investigation. (SRA | Steptoe International (UK) LLP - 635838 | Solicitors Regulation Authority).

Isil/Al-Qaeda Sanctions

• UK Government updates one entry on the UK sanctions list under the Isil (Da’esh) and Al-Qaeda regime: On 26 June, 2025, the UK government updated the entry for Abubakar Swallah on the UK sanctions list under the Isil (Da’esh) and Al-Qaeda Regime. (FCDO - UK Sanctions List Search - GOV.UK).

Counter Terrorism Sanctions

• UK court hands down first anti-terrorism sanctions conviction: On 25 June, 2025, a UK magistrates’ court ruled that Aozma Sultana had breached the UK’s Counter Terrorism Sanctions Regulations by failing to respond to multiple requests for information to OFSI.  The UK previously designated Aozma Sultana under the Counter Terrorism (Domestic) regime on 27 March 2024 in connection with her alleged involvement in providing financial support to Gaza Now, a news agency that the UK Government considered to promote Hamas and Palestinian Islamic Jihad terrorist groups. (https://www.lexology.com/pro/content/uk-secures-first-anti-terrorism-sanctions-conviction#:~:text=Westminster%20Magistrates'%20Court%20ruled%20on,following%20her%20designation%20in%202024.).

Other Sanctions

• UK Government updates sanctions guidance for non-UK businesses operating outside the UK: On 27 June, 2025, the UK Government published sanctions guidance for non-UK business operating outside the UK.  The guidance includes country-specific guides for businesses in Armenia, Georgia, Kazakhstan, Kyrgyzstan and Uzbekistan. (UK sanctions guidance for non-UK businesses operating outside the UK - GOV.UK; UK sanctions guidance for Armenian businesses - GOV.UK; UK sanctions guidance for Georgian businesses - GOV.UK; UK sanctions guidance for Kazakh businesses - GOV.UK; UK sanctions guidance for Kyrgyz businesses - GOV.UK; UK sanctions guidance for Uzbek businesses - GOV.UK).
• UK amends whistleblowing legislation to strengthen implementation and enforcement of UK sanctions: On 26 June, 2025, the Public Interest Disclosure (Prescribed Persons) (Amendment) Order 2025 came into force.  This Order amends UK whistleblowing legislation to strengthen the implementation and enforcement of UK sanctions.  In particular, the Order prescribes additional matters, including UK sanctions violations, that may be disclosed to: the Secretary of State for Business and Trade, the Secretary of State for Transport, and HM Treasury.  These amendments will help whistleblowers qualify for protections at work when disclosing information about financial, transport, and certain trade sanctions to the relevant department. (The Public Interest Disclosure (Prescribed Persons) (Amendment) Order 2025)