UK Weekly Sanctions Update - Week of March 17, 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 UK sanctions list under the Russia regime: On March 20, 2025, the UK Government amended the entry for Red Box Energy Services Pte Ltd on the UK sanctions list under the Russia regime. (Notice_Russia_200325.pdf).
• OFSI imposes £465,000 fine against law firm for breach of UK financial sanctions: On March 20, 2025, OFSI issued a £465,000 fine against Herbert Smith Freehills CIS LLP Moscow (“HSF”) for making funds available to certain UK assets freeze targets in May 2022 in breach of UK sanctions. In particular, HSF made six payments worth almost £4 million to Alfa-Bank, Sberbank and a subsidiary of Sovcombank between 25 and 31 May 2022.  According to OFSI’s penalty notice, root causes of the breach included inadequate due diligence and sanctions screening and errors causes by the hasty closure of HSF’s Russian offices. (200325_HSF_PENALTY_NOTICE.pdf).
• UK Government removes one entry from and corrected two entries under the UK sanctions list under the Russia regime: On March 19, 2025, the UK Government removed Farkhad Akhmedov from the UK sanctions list under the Russia regime. The UK Government also corrected two entries on the UK sanctions list for MCR Global Elektronik Sanayi Ve Ticaret Ltd Sirketi and Poly Technologies, Inc.. (Notice_Russia_190325.pdf).
• Trial begins for former Crimea governor charged with breaching UK sanctions: On March 18, 2025, the trial of Dmitrii Ovsiannikov, former governor of Sevastopol, began in Southwark Crown Court.  Among other things, Ovsiannikov is charged with trying to circumvent sanctions between February 2023 and January 2024.  His wife and brother are also facing charges of circumventing sanctions for their apparent roles in supporting Ovsiannikov. (https://www.reuters.com/world/europe/former-russia-appointed-governor-crimea-trial-breaching-uk-sanctions-2025-03-18/).

Belarus Sanctions

• UK Government amends one entry on UK sanctions list under the Belarus regime: On March 19, 2025, the UK Government amended the entry for Alexander Vasilevich Shakutin on the UK sanctions list under the Belarus regime. (Notice_Belarus_190325.pdf).

Global Human Rights Sanctions

• UK Government amends one entry on UK sanctions list under the Global Human Rights regime: On March 19, 2025, the UK Government amended the entry for Andrey Konstantinovich Lugovoy on the UK sanctions list under the Global Human Rights regime. (Notice_Global_Human_Rights_190325.pdf).

Other sanctions

• OFSI releases annual review for 2023-2024: On March 21, 2025, the Office of Financial Sanctions Implementation (“OFSI”) released its Annual Review for 2023-2024, which sets out OFSI’s latest efforts to drive compliance with financial sanctions through effective engagement, enhancement and enforcement. Among other things, the report noted that OFSI opened “a record number of investigations” during the reporting period, recorded 396 cases during this period, and established breaches in 20 out of 242 closed cases (8.2%).  OFSI also noted that recent enforcement actions against International Concierge Services Limited and Herbert Smith Freehills Moscow are “the first of several cases in OFSI’s pipeline which are linked to Russia’s invasion of Ukraine, with more enforcement action to come in 2025.” (OFSI_Annual_Review_2023-24.pdf; https://www.gov.uk/government/news/uk-sanctions-freeze-25bn-of-russian-assets).
• ECJU publishes notice to exporters announcing updates to the AUKUS Nations Open General Licence: On March 20, 2025, the Export Control Joint Unit (“ECJU”) published a notice to exporters announcing updates to the AUKUS Nations Open General Licence.  In particular, the general licence has been revised to align with the US excluded technologies list and includes the use of references to US terms, such as ‘manufacturing know-how’, ‘design methodology’ and ‘engineering analysis’ to allow the scope of excluded technologies to be narrowed. (NTE 2025/07: update to open general export licence - GOV.UK; https://assets.publishing.service.gov.uk/media/67dacf5fa87d546feeda0280/open-general-licence-aukus-nations.pdf).
• FCA refuses application for cryptoasset exchange provider due to weak anti-money laundering and sanctions controls: On March 17, 2025, the FCA refused Zeux Limited’s application for registration as a cryptoasset exchange provider under the Money Laundering Regulations 2017.  Among other things, the FCA’s decision notice stated that the FCA considered that the company’s customer risk assessment was inadequate and that the company could not, therefore, appropriately identify and manage/mitigate the risks of money laundering, terrorist financing and sanctions evasion that a customer may pose. (https://www.fca.org.uk/news/news-stories/fca-declines-zeux-limiteds-crypto-registration-citing-significant-risk-harm; https://www.fca.org.uk/publication/decision-notices/zeux-limited-2025.pdf).