UK Weekly Sanctions Update - Week of February 10, 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 adds five entries to and amends one entry on the UK sanctions list under the Russia regime: On February 14, 2025, OFSI added five entries to and amended one entry on the UK sanctions list under the Russia regime.  According to the UK Government, these sanctions target high profile figures working in the Russian Government and supporters of Russian state-owned business, including Pavel Fradkov, a Russian Defence Minister, Vladimir Selin, who heads up an arm of the Russian Ministry of Defence, and Artem Chaika, whose extractives company supports Russian state-owned business. (https://assets.publishing.service.gov.uk/media/67aef3f7a75f02dffca29b2b/Notice_Russia_140225.pdf; https://www.gov.uk/government/news/uk-targets-putins-inner-circle-with-new-sanctions).
• UK Government updates oil price cap general licence: On February 13, 2025, OFSI updated General licence INT/2024/4423849 to add CN / HS commodity code 2710 1944 under “premium to crude”.  At the same time, OFSI updated its guidance on the UK Maritime Services Ban and Oil Price Cap exception.  (UK Maritime Services Ban and Oil Price Cap Industry Guidance - GOV.UK; https://assets.publishing.service.gov.uk/media/67adcb642c594609b38acd24/OPC_GL_-_INT-2024-4423849_-_February_2025.pdf; https://assets.publishing.service.gov.uk/media/67adcb95e270ceae39f9e11f/Oil_Price_Cap_General_Licence_Publication_Notice_-_February_2025.pdf).
• UK Court of Appeal revokes anti-suit injunction against RusChemAlliance at UniCredit’s request: On February 11, 2025, the UK Court of Appeal granted UniCredit’s request to lift an anti-suit injunction ("ASI") it won against RusChemAlliance ("RCA"), a Gazprom joint venture, after the bank said it wanted to avoid an “eye-watering” fine from the Russian courts.  UniCredit originally obtained the ASI in January 2024 in response to RCA commencing proceedings against it in the Russian courts, in contravention of the arbitration clauses in the relevant contracts between the parties.  However, in December 2024, the Russian courts granted RCA its own ASI against UniCredit and threatened to fine UniCredit EUR 250 million if it did not cancel the UK ASI, thus increasing UniCredit's potential liability from the EUR 460 million that RCA was seeking in its Russian lawsuit to EUR 710 million.  The Court found that UniCredit’s application should be granted for four reasons: (i) UniCredit is a commercial party acting in its own interests and is entitled to tell the court it no longer needs or wants the anti-suit injunction it had previously sought and obtained, (ii) the fact that UniCredit is acting under commercial pressure is not a weighty factor in favour of refusing the order it seeks, (iii) the public policy reasons against making the order that UniCredit seeks also do not weigh heavily in the balance, and (iv) in those circumstances, it would be unjust and unfair to force UniCredit to risk massive penalties in Russia that may be avoidable if the CA’s Order is discharged or varied. (Court of Appeal Judgment Template).
• UK Government removes one entry from the UK sanctions list under the Russia regime: On February 10, 2025, OFSI removed Irina Vladimirovna Chubarova, the head of corporate finance at Gazprom Neft PJSC, from the UK sanctions list under the Russia regime. (Notice_Russia_100225.pdf)

Belarus sanctions

• UK High Court dismisses Dana Astra delisting claim: On February 11, 2025, the UK High Court dismissed a challenge brought by Dana Astra, a Belarusian construction company, in respect of its designation as a sanctions target by the Secretary of State in Dana Astra IOOO v Secretary of State for Foreign, Commonwealth and Development Affairs [2025] EWHC 289 (Admin).  The High Court found that the Human Rights Act 1998 was not engaged by Dana Astra’s designation, and that the designation was proportionate and rational in any event.  (https://caselaw.nationalarchives.gov.uk/ewhc/admin/2025/289).

Syria sanctions

• UK Government announces intention to relax certain sanctions targeting Syria:  On February 13, 2025, Minister Stephen Doughty MP issued a statement in the House of Commons stating that the Government intends to bring forward measures to adapt the Syria sanctions regime in the coming months.  According to Doughty’s statement, the anticipated amendments will include the relaxation of restrictions that apply to the energy, transport and finance sectors, and provisions to further support humanitarian delivery. Doughty also stated that "the Government remains determined to hold Bashar al-Assad and his associates to account for their actions against the people of Syria" and that the asset freezes and travel bans imposed on members of the former regime remain in force. (Update on UK Syria sanctions regime: Minister Doughty statement - GOV.UK).
• OFSI issues General Licence on humanitarian activities in Syria: On February 12, 2025, OFSI issued General Licence INT/2025/5810196, which authorises activities necessary to provide and support humanitarian assistance, and other activities that support basic needs and facilitate the timely provision of such activities in Syria, subject to certain terms and conditions.  This includes the provision, processing and payment of funds, or economic resources, and the provision of goods and services necessary to ensure the timely delivery of such assistance or to support such activities. (Syria_Humanitarian_GL_INT.2025.5810196.pdf; Syria_PN_INT.2025.5810196.pdf).

Cyber sanctions

• UK Government adds 8 entries to the UK sanctions under the cyber sanctions regime: On February 11, 2025, OFSI added eight entries to the UK sanctions list under the Cyber sanctions regime, namely ZSERVERS, six of its members, and its UK front company XHOST.  According to the UK Government, ZSERVERS is a key component of the Russian cybercrime supply chain, and these measures strengthen UK national security. (Notice_Cyber_110225.pdf; https://www.gov.uk/government/news/new-uk-sanctions-target-russian-cybercrime-network).

Other sanctions

• UK Government intends to press other nations to develop people smuggling sanctions regimes: On February 14, 2025, Foreign Secretary David Lammy urged foreign partners at the Munich Security Council to replicate the UK's world-first plans for a sanctions regime aimed at targeting organised immigration crime gangs and their networks.  The UK Government announced plans on January 8, 2025, to freeze the assets and provide travel bans on smugglers who facilitate in human trafficking and starve them of illicit finance was the first of its kind in the world.  According to Lammy, "criminal gangs enabling irregular migration are a national security threat across Europe [and]… only by working together with our neighbours will we take the wind out of their sails and degrade the appalling trade in people". (European partners urged to develop sanctions to smash people smuggling gangs - GOV.UK).
• UK Government publishes Financial Services Threat Assessment Report:  On February 13, 2025, OFSI published its Financial Services Threat Assessment Report, one in a series of sector-specific assessments addressing threats to UK financial sanctions compliance. The report identifies key evasion threats, red flags that businesses should be aware of, and recommendations on how to mitigate the identified risks. (OFSI_Financial_Services_Threat_Assessment_Report.pdf).
• UK Government calls for expressions of interest to conduct review of evidence on sanctions: On February 13, 2025, the UK Government invited expressions of interest from organisations to commission a theory-building systematic review of the research literature on the circumstances in which autonomous targeted sanctions, and other diplomatic measures, are effective in preventing conflict and atrocity in low- and middle-income countries.  The funding offered to eligible organisations is between £10,001 and £100,000 and organisations are required to respond by February 28, 2025. (Systematic review of evidence on sanctions: expressions of interest - GOV.UK).
• SRA publishes guidance on trade sanctions for legal sector: On February 5, 2025, the Solicitor’s Regulation Authority issued guidance on trade sanctions.  The guidance sets out key risks for the legal sector, including areas of legal work that would be affected by trade sanctions.  (https://www.sra.org.uk/sra/news/sra-update-136-trade-sanctions/)