UK Weekly Sanctions Update - Week of March 3, 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 one entry on and removes two entries from the UK sanctions list under the Russia sanctions regime: On March 7, 2025, OFSI removed Rosbank PJSC, a Russian financial services firm, and Active Denizcilik Ve Gemi Isletmeciligi Anonim Sirket, a Russian energy company, from the UK sanctions list under the Russia sanctions regime.  OFSI also amended the entry for Tinkoff Bank, updating its name to TBank. (Notice_Russia_070325.pdf)

Syria sanctions

• UK Government removes 24 entries from the UK sanctions list under the Syria sanctions regime: On March 6, 2025, OFSI removed 24 entries from the UK sanctions list under the Syria sanctions regime.  The de-listings include the Central Bank of Syria, the Commercial Bank of Syria, Syrian Arab Airlines and certain Syrian energy companies.  According to the UK Government, the de-listings lift asset freezes on "24 Syrian entities that were previously used by the Assad regime to fund the oppression of the Syrian people" to help "the people of Syria rebuild their country and economy".  (Update on Syria: Lifting asset freezes on 24 entities - GOV.UK; Notice_Syria_060325.pdf)
• UK Government updates Syria sanctions guidance: On March 7, 2025, OFSI updated the Syria sanctions guidance to reflect the new service name for licence applications for the import of goods. In particular, references to 'Import Case Management System' have been updated to 'Apply for an import licence'. (Syria sanctions: guidance - GOV.UK)

Somalia sanctions

• UK Government updates Somalia sanctions guidance: On March 7, 2025, OFSI updated the Somalia sanctions guidance to reflect the new service name for licence applications for the import of goods.  In particular, references to 'Import Case Management System' have been updated to 'Apply for an import licence'. (Somalia sanctions: guidance - GOV.UK)

Other sanctions

• HMRC announces £375,000 compound settlement relating to the unlicensed export of dual-use goods: On March 4, 2025, the Export Control Joint Unit (“ECJU”) published a Notice to Exporters stating that HM Revenue and Customs (“HMRC”) issued in October 2024 a compound settlement offer to a UK company worth £374,326.07.  The settlement related to unlicensed exports of dual-use goods and a failure to declare licences to customs.  The Notice to Exporters notes that HMRC has seen in the past 12 months an increased in the number of voluntary disclosures relating to: (i) unlicenced exports; (ii) incorrect licence usage, and (iii) breach of licence conditions. (https://www.gov.uk/government/publications/notice-to-exporters-202505-compound-settlement-offer-for-breaches-of-export-control/nte-202505-compound-settlement-offer-for-breaches-of-export-control)
• HMRC response to Chair of Treasury Select Committee indicates focus on Russia sanctions breaches: A letter dated February, 17, 2025 from HMRC responding to enquiries from the Dame Meg Hillier MP, Chair of the Treasury Select Committee, set out in a letter dated January 30, 2025 provides insight into HMRC’s role in enforcing UK sanctions and how it coordinates with other UK agencies.  Among other things, the letter reveals that: (i) there has been a significant uptick in new investigations opened into potential sanctions offences (65 since 2022, all relating to Russia); (ii) between 2021 and 2024, six compound penalties for breaches of Russia sanctions were issued and one for breaches of Iran sanctions; and (iii) HMRC has 30 live criminal investigations into breaches of sanctions, 27 of which related to Russia sanctions. (https://committees.parliament.uk/publications/46714/documents/240633/default/)