Sanctions and export control | UK Regulatory Outlook June 2025

OFSI new video guidance series 

The Office of Financial Sanctions Implementation (OFSI) published a new video series "Financial Sanctions: The Basics", intended to provide detail to help individuals and companies comply with UK financial sanctions. The videos cover the following topics: 

• an introduction to OFSI and its work, and how financial sanctions work;
• an overview of the range of guidance published by OFSI;
• an explanation of how OFSI and the Foreign Commonwealth and Development Office (FCDO) work together when there are new sanctions designations and what firms should do following when an individual has been designated;
• what to do in the event of a suspected financial sanctions breach and how to make effective reports to OFSI;
• who may use a general licence and how they work; and
• what a specific licence is and how to apply for one. 

OFSI publishes art market participants and high value dealers threat assessment report 

OFSI published its art market participants (AMPs) and high value dealers (HDVs) threat assessment report, which covers threats to financial sanctions compliance of relevance to AMPs and HDVs.  

This is the fourth in a series of sector-specific reports published by the OFSI identifying issues with sanctions compliance and red flags which should trigger enhanced due diligence and, where relevant, reports to OFSI. It follows the expansion of mandatory financial sanctions reporting under the UK sanctions regime to include "relevant firms" such as AMPs and HVDs, which came into force on 14 May 2025.  

The report is focused on providing AMPs and HVDs with guidance on examples of reporting best practice as well as red flags indicative of activities and sector-specific threats relevant to AMPs and HVDs. It is intended to assist stakeholders with prioritisation as part of a risk-based approach to compliance. 

OFSI stated that it expects AMPs and HVDs to begin reporting high value goods which are also frozen assets, following the introduction of reporting obligations. The report also emphasised that AMPs and HVDs of all sizes must comply with the existing anti-money laundering in addition to the newly introduced financial sanctions reporting obligations. For further information, see OFSI's guidance and webinar. 

See also our previous updates on the financial services and property and related services threat assessment reports. Our Insight explains the reporting obligations affecting firms in the property sector. 

If you have any questions or concerns about the threat assessment or would like to discuss your new reporting obligations, please get in touch with your usual Osborne Clarke contacts or our experts below. 

Amendments to Public Interest Disclosure Order 2014 to cover sanctions 

The Public Interest Disclosure (Prescribed Persons) (Amendment) Order 2025, which comes into force 26 June 2025, makes amends to Public Interest Disclosure (Prescribed Persons) Order 2014 to expand matters that can be disclosed to the secretary of state for Business and Trade and secretary of state for Transport to include sanctions. HM Treasury has also been added as a prescribed person to whom whistleblowing disclosures can be made in relation to financial sanctions. 

See the government guidance page for more information on how the changes apply in relation to trade sanctions. 

OFSI general licences 

OFSI amended the following general licences: 

• General Licence INT/2023/3263556: which allows payments and other permitted activities to take place in relation to insolvency proceedings associated with GTLK Europe and GTLK Capital and their subsidiaries. The general licence has been amended to add new definitions, a reporting requirement and changes to clarify various permissions. This general licence takes effect from and 1 August 2023 and expires on 31 July 2030.  

UK-EU Security and Defence Partnership 

The UK and EU has agreed new Security and Defence Partnership, which aims to enhance cooperation and dialogue on defence, including maritime security, critical infrastructure and illicit finance. As part of the partnership, the UK and EU agreed to continue to cooperate and explore opportunities to collaborate further on sanctions policy, with a particular focus on regions including Ukraine, the wider Eastern European Neighbourhood (the Black Sea, the Western Balkans, the Arctic, the Middle East and Africa).