UK Weekly Sanctions Update - Week of February 24, 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 corrects one entry on the UK sanctions list under the Russia regime: On February 28, 2025, OFSI corrected the address for OJSC Keremet Bank on the UK sanctions list under the Russia sanctions regime. (Notice_Russia_280225.pdf).
• UK Government publishes factsheet on UK Support to Ukraine: On February 28, 2025, the UK Government published a factsheet which details the UK's support to Ukraine.  Among other things, the factsheet notes that, since Russia's full-scale invasion of Ukraine in 2022, the UK Government has designated over 2,000 individuals and entities, including members of Putin's inner circle and two of the Russia's largest oil companies and more than 140 vessels. (UK_support_to_Ukraine_factsheet.pdf).
• General Licence on Russian Oil Majors Wind Down expires:  On February 27, 2025, General Licence INT/2025/5635701 expired.  The General Licence authorised the wind down or divestment from any transactions involving Gazprom Neft and PJSC Surgutneftegas or any entity owned or controlled by either of them following their designation as a UK sanctions target on January 10, 2025. (INT.2025.5635701_GL.pdf).
• UK Government corrects five entries on the UK sanctions list under the Russia regime: On February 27, 2025, OFSI corrected the entries for two individuals (Vasily Abramov and Natalya Tyurina) and three entities (JSC Siberia Airlines, Monolink Group and OJSC Keremet Bank) on the UK sanctions list under the Russia sanctions regime. (https://assets.publishing.service.gov.uk/media/67c05af4a0f0c95a498d205b/Notice_Russia_270225.pdf).
• UK Government removes one entry from the UK sanctions list under the Russia regime:  On February 26, 2025, OFSI removed Francois Edouard Mauron from the UK sanctions list under the Russia regime.  Mauron was designated in November 2023 for obtaining a benefit from or supporting the Government of Russia by working as a director in a business of strategic significance to Russia's energy sector. (Notice_Russia_260225.pdf).
• UK Government updates guidance on countering Russian sanctions evasion: On February 25, 2025, OFSI updated its guidance on countering Russian sanctions evasion, which seeks to support UK exporters in understanding Russian circumvention practices and mitigate the risk of businesses being targeted by those seeking to evade sanctions.  The updated guidance provides additional information on the level of risk the government is willing to accept when assessing export licence applications for Common High Priority List items subject to export controls, where there is a lack of certainty regarding the end-use or end user (such as items destined for stock), and where the UK Government assesses there is a risk of diversion to Russia. (Countering Russian sanctions evasion - guidance for exporters - GOV.UK; https://www.gov.uk/government/publications/notice-to-exporters-202503-update-to-countering-russian-sanctions-evasion-and-circumvention-guidance/nte-202503-update-to-countering-russian-sanctions-evasion-and-circumvention-guidance).
• UK Government imposes more than 100 new sanctions under the Russia regime: On February 24, 2025, the UK Government added 67 new entries to the UK sanctions list and specified 40 new ships under the Russia regime.  According to the UK Government, these designations mark the "largest sanctions package against Russia since 2022" which, according to Foreign Secretary David Lammy, "underscores the UK's commitment to Ukraine".  Amount the designations were producers of machine tools, electronics and dual-use goods for Russia's military who are predominately based in third countries, including Central Asian states, Turkey and China.  13 designations have also been made against Russian targets who have been cited as companies which are being used to funnel advanced European technology into Russia to support the war.  (UK announces largest sanctions package against Russia since 2022 - GOV.UK; Notice_Russia_240225.pdf).

Global Anti-Corruption sanctions

• UK Government amends one entry on the UK sanctions list under the Global Anti-Corruption regime: Ob February 28, 2025, OFSI amended the entry for Teodoro Nguema Obiang Mangue.  The entry was amended to include the grounds in which Teodoro Nguema Obiang Mangue is an "involved person" within the meaning of the Global Anti-Corruption Sanctions Regulations 2021, including but not limited to being involved in "serious corruption". (Notice_Global_Anti_Corruption_280225.pdf).

Other sanctions

• ECJU removes Rwanda as permitted destination from four OGELs:  On February 26, 2025, the Export Control Joint Unit (“ECJU”) removed Rwanda as a "permissible destination" on four Open General Export Licences ("OGELs").  The relevant OGELs relate to: the export of military goods for demonstration; export for repair/replacement under warranty; printed circuit boards and components for military goods; and software and source codes for military goods. (NTE 2025/04: changes to permitted destinations on 4 open general licences - GOV.UK; Open general export licence military goods: for demonstration - GOV.UK; Open general export licence export for repair/replacement under warranty: military goods - GOV.UK; Open general export licence software and source code for military goods - GOV.UK; Open general export licence PCBs and components for military goods - GOV.UK).
• ECJU adds Greece as permitted destination to Joint Strike Fighter OGEL: On February 24, 2025, the Export Control Joint Unit added Greece as a “permitted destination” for the Joint Strike Fighter: F-35 Lightning II open general export licence. (https://www.gov.uk/government/publications/notice-to-exporters-202502-update-to-open-general-export-licence/nte-20252402-update-to-open-general-export-licence).