UK Weekly Sanctions Update - Week of July 7, 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

• HMRC agrees £1 million compound settlement in relation to breaches of Russia sanctions: On July 8, 2025, HMRC published details of a compound settlement in relation to a UK exporter that made goods available to Russia in breach of The Russia (Sanctions) (EU Exit) Regulations 2019. The compound settlement involved a penalty of £1,160,725.67 which was paid to HMRC in May. This is the largest compound settlement HMRC has concluded for a Russia sanctions offence. (NTE 2025/18: compound settlement for breaches of export control - GOV.UK).
• UK issues Red Alert on Russia ‘shadow fleet’ sanctions evasion and avoidance network: On July 6, 2025, the UK Government published a Red Alert on shadow fleet sanctions evasion and avoidance.  Issued jointly by the National Crime Agency (NCA), the National Economic Crime Centre (NECC), and OFSI among others, the Red Alert provides information to assist financial institutions in identifying potential sanctions evasion in relation to the sale of Russian oil and gas. (NCA - Red Alert).

Chemical Weapons sanctions

• UK Government adds three entries to the UK sanctions list under the Chemical Weapons sanctions regime: On 7 July, 2025, OFSI added two individuals, Andrei Marchenko and Aleksey Viktorovich Rtishchev, and one entity, Joint Stock Company Federal Scientific and Production Centre Scientific Research Institute of Applied Chemistry, under the Chemical Weapons sanctions regime. (Notice_Chemical_Weapons_07072025.pdf).

Haiti sanctions

• UK Government adds two individuals to the UK sanctions list under the Haiti sanctions regime: On 10 July 2025, OFSI added Gran Grif and Viv Ansanm to the UK sanctions list under the Haiti Sanctions Regime. (Notice_Haiti_100725.pdf).

Other sanctions

• OFSI publishes new FAQ on its interpretation of “domiciled”: On July 10, 2025, OFSI published FAQ 153, which addresses how OFSI applies the term ‘domisiled’ in financial sanctions regulations.  FAQ 153 states that OFSI applies the term “domiciled” on a case-by-case basis and considers all available evidence when forming a view.  Relevant factors include an entity’s place of incorporation and constitution, its registered office and the controlling shareholders or directors.  The FAQ states that the domicile of a subsidiary company is independent to that of its parent company. (https://www.gov.uk/government/publications/uk-financial-sanctions-faqs/uk-financial-sanctions-faqs).
• Monzo Bank fined £21 million for “inadequate” anti-financial crime systems.  On July 8, 2025, the FCA announced that it had imposed a fine of £21,091,300 against Monzo for inadequate anti-financial crime systems and controls between October 2018 and August 2020.  Among other things, Monzo failed to design, implement and maintain adequate customer onboarding, customer risk assessment and transaction monitoring systems to mitigate the risk of financial crime. (https://www.fca.org.uk/news/press-releases/fca-fines-monzo-21m-failings-financial-crime-controls; https://www.fca.org.uk/publication/final-notices/monzo-bank-limited.pdf).
• OFSI updates General Guidance with new HM Treasury debt exception: On July 9, 2025, OFSI published guidance on a new exception that allows payments in respect of HM Treasury debt to be made to, or for the benefit of, individuals designated by the United Nations, provided that the payment obligation arose prior to the individual’s designation and that the funds are paid into an account specified by the exception, such as a frozen UK account or an account in a corresponding jurisdiction. (The Sanctions (EU Exit) (Treasury Debt) Regulations 2025).
• The SRA begins annual AML and sanctions data collection: On July 8, 2025, the Solicitors Regulation Authority (SRA) announced that it is conducting an annual exercise to collect data on anti-money laundering (AML) and sanctions from regulated firms. Between July 7 and August 15, firms are required to supply details to the SRA relating to their AML controls, activities related to financial sanctions, and any interactions or involvement with the sanctions regime. The responses will help the SRA better understand where risks lie and how it can allocate resources to respond to those risks.  In addition, the responses will assist the SRA in its supervision of the legal sector. (SRA | SRA Update issue 140 - June 2025 | Solicitors Regulation Authority).
• FCA annual report 2024/25 reveals FCA conducted 266 sanctions compliance assessments last year: In July 2025, the FCA released its annual report for FY25.  Among other things, the report states that the FCA conducted 266 sanctions compliance assessments in FY25 (up from 248 in the previous year), fines Starling Bank £29 million for financial crime failures in its financial sanctions controls and screening, and fined Metro Bank plc £16.7 million for deficiencies in transaction monitoring to address money laundering risks. (https://www.fca.org.uk/publication/annual-reports/annual-report-2024-25.pdf).