UK Weekly Sanctions Update - Week of April 7, 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 concludes first prosecution for breaches of Russia sanctions: On April 11, 2025, Dmitrii Ovsyannikov and Alexei Ovsyannikov were prosecuted for breaches of Russian linked financial sanctions for the first time ever in the United Kingdom.  Among other things, Alexei purchased a car for and paid private school fees on behalf of his brother, Dmitrii, a UK sanctions target, making funds available to Dmitrii in contravention of UK financial sanctions.  They were each found guilty of either counts or breaching financial sanctions and two counts of money laundering, and were sentenced to 40 and 15 months imprisonment, suspended for 15 months, respectively.  (https://www.cps.gov.uk/cps/news/sentencing-first-ever-uk-prosecution-russian-sanction-breaches; https://www.nationalcrimeagency.gov.uk/news/nca-secures-first-convictions-for-breach-of-uk-sanctions)
• Minister responds to written question relating to assets associated with Chelsea Football Club: On April 7, 2025, Stephen Doughty MP, Minister of State (FCDO), responded to a written question asking whether the UK Government plans to apply further sanctions to assets associated with the owners and affiliated entities of Chelsea Football Club and other Russian individuals/entities.  The Minister stated that the Government will not comment or speculate on further designations, but noted that the Government is determined to see the proceeds from the sale of Chelsea FC reach humanitarian causes in Ukraine as soon as possible. (https://questions-statements.parliament.uk/written-questions/detail/2025-03-27/41840)

Global Human Rights Sanctions 

• UK Government adds four entries to UK sanctions list under the Global Human Rights Sanctions Regime: On April 10, 2025, the UK Government added four individuals (Shalva Bedoidze, Giorgi Gabitashvili, Karlo Katsitadze, and Mirza Kezevadze) to the UK sanctions list under the Global Human Rights Sanctions Regime. According to the UK government, these measures target Georgian officials responsible for allowing serious human rights violations under the Global Human Rights Sanctions Regulation 2020. (Notice_Global_Human_Rights_10042025.pdf)

Counter-Terrorism Sanctions

• UK Government amends four entries on the UK sanctions list under the Counter-Terrorism Regime: On April 9, 2025, the UK Government amended entries for four individuals (Mohammed Fawaz Khaled, Aozma Sultana, Nazem Ahmad, Mustafa Ayash) on the UK sanctions list under the Counter-Terrorism Sanctions Regime. (Notice_Counter_Terrorism__Domestic__090425.pdf)

Other Sanctions

• OFSI publishes Property and Related Services Threat Assessment: On April 10, 2025, OFSI published a report outlining its assessment of threats to sanctions compliance involving Property and Related Services providers since February 2022.  The report notes that, since February 2022, 7% of suspected breaches reported to OFSI involved property and related services firms.  Among the key judgements set out in the report, OFSI states that: (i) it is almost certain that UK property and related services providers have underreported suspected breaches of financial sanctions to OFSI; (ii) it is almost certain that that DPs have breached UK financial sanctions by making or facilitating transactions for the benefit of their UK properties without an OFSI licence or applicable exception; (iii) it is highly likely that property-related suspected breach activity by or on behalf of Russian DPs has been facilitated by small-scale property or related services firms with high-risk appetites and longstanding relationships with DPs; (iv) it is highly likely that DPs, particularly Russian DPs, have used intricate layers of ownership to distribute their wealth by placing property under the ownership and control of their family members; and (v) it is almost certain that UK property and related services firms have acted as professional enablers for DPs, thus facilitating sanctions breaches. (OFSI_Property_and_Related_Services_Threat_Assessment.pdf)
• UK government publishes director disqualification sanctions guidance, imposes director disqualification sanctions against more than 3800 entries: On April 8, 2025, the UK Government published general guidance on director disqualification sanctions, which inter alia ban designated individuals from bring a director of a UK company. On April 9, 2025, the UK government varied the designations of 2996 individuals and 818 entities to make those entries subject to director disqualification sanctions. (Director disqualification sanctions - GOV.UK)
• ECJU agrees three compound settlements worth more than £3.6m for breaches of export control: On April 9, 2025, the Export Control Joint Unit (“ECJU”) published a notice to exporters NTE 2025/08 reporting on compound penalties entered into by HM Revenue and Customs (HMRC) during Q1 of 2025. During this period, £10,900.00 was paid for export license breaches in relation to the export of military goods (in January 2025), £431,232.20 was paid relating to the unlicensed exports of military goods (in February 2025) and £3,231,762.40 was paid relating to the unlicensed exports of military goods (in February 2025). (https://www.gov.uk/government/publications/notice-to-exporters-202508-agreed-compound-settlement-for-breaches-of-export-control/nte-202508-agreed-compound-settlement-for-breaches-of-export-control)