UK Weekly Sanctions Update - Week of July 21, 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 amends two entries on the UK sanctions list under the Russia regime: On July 24, 2025, OFSI made administrative amendments to two entries on the UK sanctions list under the Russia sanctions regime, namely Litasco Middle East DMCC and the Victor Konetsky, a specified ship.  (https://assets.publishing.service.gov.uk/media/688201fef47abf78ca1d35d7/Notice_Russia_240725.pdf).
• UK government adds two entities to the UK sanctions list and specifies 135 ships under the Russia regime: On July 21, 2025, the UK added two entities, Intershipping Services LLC and Litasco Middle East DMCC, to the UK sanctions list and specified 135 ships under the Russia regime. At the same time, the entries on for Yegor Yurievich Karasev and OJSC Keremet Bank were updated on the UK sanctions list. (Notice_Russia_210725.pdf; UK hammers Putin's energy revenues with fresh sanctions - GOV.UK).
• ECJU publishes general trade licence for the transfer of sectoral software and technology to Russia: On July 21, 2025, the ECJU published Notice to Exporters 2025/22 announcing the issuance of a General Trade Licence that permits inter the transfer of technology of business enterprise software and technology and the making available of business enterprise software and technology and ancillary services relating to business enterprise software and technology prohibited by Chapter 4N of the Russia (Sanctions) (EU Exit) Regulations 2019, subject to certain terms and conditions. This General Trade Licence expires on 20 October 2025. (NTE 2025/22: general trade licence Russia sanctions – sectoral software and technology - GOV.UK; General trade licence Russia sanctions – sectoral software and technology - GOV.UK).
• UK issues general licence relating to the continuation of business Intershipping Services LLC under the Russia regime: On July 21, 2025, the UK Government issued General Licence INT/2025/6403704, which authorises vessels owned or operated by, or on behalf of, the Government of the Gabonese Republic, to continue certain business operations with Intershipping Services LLC, the authorised representative for the Maritime Administration of the Gabonese Republic.  The General Licence is of indefinite duration. (Intershipping_Services_LLC_Business_Continuity_GL.pdf; Intershipping_Services_LLC_Business_Continuity_PN.pdf).
• UK issues general licences relating to the wind down of positions involving Intershipping Services LLC and Litasco Middle East DMCC under the Russia regime: On July 21, 2025, the UK Government issued General Licence INT/2025/6397444, which authorises the wind down of transactions involving Intershipping Services LLC, and General Licence INT/2025/6488808, which authorises the wind down of positions involving Litasco Middle East DMCC. Each General Licence expires on September 18, 2025. (https://assets.publishing.service.gov.uk/media/687e16f7211264fc8bb2f729/Intershipping_Services_LLC_Wind_Down_GL.pdf; https://assets.publishing.service.gov.uk/media/687e154b2f42aece1f8fbfba/Litasco_Wind_Down_GL.pdf).

Global Irregular Migration and Trafficking in Person Sanctions

• UK government adds 25 entries to the UK sanctions list under the Global Irregular Migration regime: On July 23, 2025, the UK government added 5 entities and 20 individuals to the UK sanctions list under the Global Irregular Migration sanctions regime. According to the UK Government, the designations targeted gang ring leaders, key intermediaries and supplies of people-smuggling equipment.  This includes parties involved in supplying small boats for smuggling, sourcing fake passports, facilitating illicit payments through Hawala and people-smuggling via lorries and small boards. (Notice_Global_Irregular_Migration_and_Trafficking_in_Persons_230725.pdf; UK sanctions notorious people-smuggling gangs and their enablers in global crackdown - GOV.UK).
• UK government adds Global Irregular Migration and Trafficking in Persons regime to scope of Basic Necessities and Asset Recovery General Licences: On July 23, 2025, OFSI expanded General Licence INT/2025/5632740, which authorises certain dealings with a designated person within two months of their designation for basic necessities within two months of the date of their designation, and General Licence INT/2022/1679676, which authorises certain dealings with a designated person in connection with law enforcement asset recovery efforts to apply to parties designated under the Global Irregular Migration and Trafficking in Persons regime. (Basic_Necessities_General_Licence_INT.2025.5632740.pdf; https://assets.publishing.service.gov.uk/media/688096a477a3acd9f4d0e276/Interim_Basic_Necessities__Publication_Notice_INT.2025.5632740.pdf ; INT20221679676_GL_GIMTiPS.pdf; https://assets.publishing.service.gov.uk/media/68809717f2ecaeb756d0e280/INT20221679676_PN_GIMTiPS.pdf).
• UK government launches Global Irregular Migration and Trafficking in Person regime: On July 22, 2025, the UK government announced the launch of a new sanctions regime targeting persons anyone complicit in facilitating people smuggling to the UK.  Using the powers conferred by the Sanctions and Anti-Money Laundering Act the Government laid secondary legislation before Parliament that introduces a new Global Irregular Migration and Trafficking in Persons sanctions regime. (UK brings forward world’s first sanctions regime to smash the gangs responsible for irregular migration - GOV.UK).

Other sanctions

• OFSI adds licensing ground for return of funds to non-designated persons from designated money services businesses: On July 23, 2025, Section 6.6 of OFSI’s General Guidance was updated to include a licensing ground permitting OFSI to issue a licence to allow funds to be returned to a non-designated person from a designated money service business, subject to certain terms and conditions. (https://www.gov.uk/government/publications/financial-sanctions-general-guidance/uk-financial-sanctions-general-guidance?).
• OFSI launches consultation on enforcement policies and processes: On July 22, 2025, OFSI launched a consultation to seek views on proposed changes to its enforcement policies and processes. OFSI has identified revisions to its enforcement processes that could enable it to resolve cases more efficiently, improving the delivery of public enforcement actions and reducing burdens on OFSI and on subject firms or individuals. Among other things, OFSI is seeking views on: changes to its public case assessment guidance and penalty discounts for voluntary disclosure and co-operation; the introduction of various schemes to streamline the investigation and settlement process; and changes to OFSI’s statutory maximum penalties. The consultation will run until October 13, 2025. (Improving civil enforcement processes for financial sanctions - GOV.UK).
• OFSI publishes cryptoassets threat assessment report: On July 21, 2025, OFSI published its Cryptoassets Threat Assessment Report. The report identifies key evasion threats, red flags that businesses should be aware of, and guidance on areas where compliance could be strengthened.  Among other things, OFSI determined that: it is almost certain that UK cryptoasset firms have under-reported suspected breaches of financial sanctions to OFSI since August 2022; it is likely that most non-compliance by UK cryptoasset firms has occurred inadvertently due to common issues such as direct and indirect exposure to designated persons and suspected breaches being identified after a delay in attribution; and it is highly likely that UK cryptoasset firms have been directly or indirectly exposed to the designated Russian exchange Garantex since its designation in 2023, resulting in breaches of UK financial sanctions. (https://assets.publishing.service.gov.uk/media/687e637292957f2ec567c625/OFSI_Cryptoassets_Threat_Assessment.pdf).
• ECJU publishes Notice to Exporters updating End User Undertaking and guidance: On July 21, 2025, the ECJU published NTE 2025/20, which states that the ECJU has updated the end user undertaking form, which must be completed for a standard individual export licence, standard individual trade control licence, or licence to provide technical assistance. (https://www.gov.uk/government/publications/notice-to-exporters-202520-updated-end-user-undertaking-euu-and-guidance).
• ECJU publishes Notice to Exporters updating F680 approval for classified and unclassified ITAR material: On July 21, 2025, the ECJU published NTE 2025/21, which describes inter alia what information must be included in a SPIRE application for unclassified ITAR F680 approvals. (https://www.gov.uk/government/publications/notice-to-exporters-202521-f680-approval-for-classified-and-unclassified-itar-material/nte-202521-f680-approval-for-classified-and-unclassified-itar-material).