UK Weekly Sanctions Update - Week of January 20, 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 Court of Appeal dismisses Anzhelika Khan’s appeal to overturn sanctions: On January 24, 2025, the UK Court of Appeal ("UKCA") dismissed an appeal from Anzhelika Khan to overturn her designation as a UK sanctions target under the Russia regime.  Mrs Khan, a Russian-born British citizen, was designated under the Russia sanctions regime on April 21, 2022 for having obtained a "financial benefit or other material benefit" from her husband, German Khan, an oligarch and co-founder of Alfa Group, a Moscow-based conglomerate which controls the largest commercial bank and biggest food retailer in Russia.  The UKCA did not accept Mrs Khan's argument that her designation was not related to the sanctions' purpose, ruling that less intrusive measures would compromise the objective of the sanctions regime.  (Wife of Ukrainian-Russian businessman Khan loses UK sanctions appeal | Reuters, Court of Appeal Judgment Template).
• UK Government reveals it has 318 open investigations into breaches of Russia financial sanctions: On January 23, 2025, the UK Government stated that: (i) OFSI currently has 318 investigations open relating to potential breaches of the Russia sanctions regime; and (ii) OFSI has investigated and closed 388 cases relating to potential breaches of the Russia sanctions regime since February 2022.  (https://www.parallelparliament.co.uk/question/24637/sanctions-russia).
• UK publishes briefing paper on sanctions against Russia: On January 21, 2025, a House of Commons research briefing was published on sanctions against Russia from February 2022 to January 2025.  The briefing provides an overview of the sanctions that have been imposed on Russia between February 2022 and January 2025 by the UK, EU, US and other major allies and partners.  (Sanctions against Russia (February 2022 to January 2025) - House of Commons Library).

Syria Sanctions

• UK Government amends Syria sanctions guidance: On January 23, 2025, the UK Government updated its Syria sanctions guidance to reflect the amendments previously made by the Sanctions (EU Exit) (Miscellaneous Amendments) (No. 2) Regulations 2024.  Among other things, those regulations: (i) changed the existing requirements on "relevant firms" and "involved persons" to report suspected offences to a requirement to report suspected breaches of sanctions regulations and (ii) created a new insolvency licensing purpose under certain UK sanctions regimes. (Syria sanctions: guidance - GOV.UK).

Other Sanctions

• UK Government amends guidance on reporting a suspected breach of trade sanctions: On January 24, 2025, the Office of Trade Sanctions Implementation (OTSI) updated its guidance on reporting suspected breaches of trade sanctions.  The update provides guidance where a report relates to a person or business other than the reporting person.  (Report a suspected breach of trade sanctions - GOV.UK).