Sanctions and export control | UK Regulatory Outlook March 2026

UK government publishes strategic approach to sanctions enforcement 

The government has published a policy paper outlining its strategic approach to the civil and criminal enforcement of breaches of UK sanctions. It includes the four key enforcement principles, mitigating and aggravating factors in enforcement, and the roles of key government departments, regulators and enforcement bodies. The paper fulfils a commitment made in a cross-government review of sanctions implementation and enforcement to help industry understand the consequences of non-compliance with sanctions regulations. 

UK government publishes summaries of sanctions regimes 

The government has published summaries of UK sanctions regimes with the aim of helping businesses and organisations understand what sanctions are and how they work. 

The new summaries give an overview of the sanctions in place under a particular regime, covering, where applicable:  

• the regime’s scope;
• what applies to designated persons and specified ships;
• wider financial and trade sanctions;
• sanctions on goods and services; and
• additional sanction types. 

These regime summaries are not intended to be comprehensive, and organisations should continue to refer to the relevant statutory guidance and regulations. 

OFSI publishes blog on licence application prioritisation framework 

The Office of Financial Sanctions Implementation (OFSI) has published a blog post on how it prioritises applications for sanctions licences. 

Due to the high volume of applications OFSI receives (900 licensing decisions were made in the year 2024–2025), it is unable to deal with all applications immediately. By publishing its prioritisation framework, it hopes to help applicants understand how applications are prioritised, and urges applicants to submit licence applications well in advance, wherever possible, as complexities may mean that even an urgent licence application can take time to process. 

The blog post sets out the seven criteria against which licence applications are assessed, and provides advice on how applicants can help OFSI process their applications more efficiently by submitting clear, complete and well-evidenced information. 

OFSI publishes blog on 'reasonableness' in licence applications  

OFSI has published a blog post which sets out how it assesses "reasonableness" in licence applications under UK financial sanctions regimes. It should be read alongside its June 2021 guidance on reasonableness in licensing and its general guidance.  

The updated guidance covers: 

Legal services: Costs Draftsperson’s Reports  

Where applications for legal fees relate to ongoing, complex matters, OFSI will now require an independent Costs Draftsperson's Report (CDPR) to be submitted as part of the application in certain circumstances.  

A CDPR is mandatory where, within any six-month period, total legal and counsel fees (instructed via solicitors) exceed £2 million (inclusive of VAT), or where counsel instructed directly exceeds £1 million. These thresholds apply per firm or counsel, per designated person, and accumulate across all related applications. 

Maintenance of frozen funds and economic resources licensing ground 

For high-value, novel, or complex maintenance applications, such as those relating to superyachts or significant construction works, applicants are now encouraged to submit an independent expert report, which OFSI may require on a case-by-case basis.  

Evidence to demonstrate reasonableness  

OFSI states that evidence submitted to demonstrate reasonableness should generally be no more than six months old. Where evidence older than six months is relied upon, applicants must provide an explanation of why more recent evidence could not be obtained and why it remains reliable as a basis for assessing reasonableness. 

Court of Appeal upholds UK sanctions designation against Belarusian developer 

The Court of Appeal has unanimously dismissed an appeal by Dana Astra IOOO (DANA), one of Belarus's largest real estate developers, against its designation under the Republic of Belarus (Sanctions) (EU Exit) Regulations 2019, upholding the High Court's decision. 

DANA was designated in December 2020 on the basis of its sponsorship of the Belarusian National Olympic Committee and its involvement in the Belarusian construction sector — a sector of strategic significance to the Lukashenko regime. It brought a review application under section 38 of the Sanctions and Anti-Money Laundering Act 2018, arguing the designation was disproportionate and irrational. 

The Court of Appeal held: 

• DANA, a company with no presence, business or assets in the United Kingdom, was not "within the jurisdiction" of the UK for the purposes of Article 1 of the European Convention on Human Rights (ECHR). It noted that Article 1 "requires control over the person himself or herself rather than the person's interests as such", and that to hold otherwise would "entail a radical departure from established principles under Article 1."
• Rejecting DANA's argument that potential future "goodwill" in a business yet to be started in the UK could bring it within the ECHR's jurisdictional reach, the court observed that on DANA's logic any company anywhere in the world wishing to do business in the UK would be "within the jurisdiction" for Article 1 purposes. Goodwill is limited to the "marketable and presently capitalisable product of a business's past work and reputation". DANA had no such goodwill in the UK. 

See the press release. 

OTSI publishes guidance on countering Russian sanctions evasion 

The Office of Trade Sanctions Implementation (OTSI) has published updated guidance to support UK businesses in understanding Russian circumvention practices and reducing the risk of their businesses being targeted by those seeking to evade sanctions. 

The UK goods at higher risk of circumvention list has been amended to include machines for crushing or grinding earth, stone, ore or other mineral substances; enamel and lacquers; and heterocyclic compounds containing a pyrimidine ring or a piperazine ring in the structure. 

Israel has also been added to the list of third-country exporters in respect of which businesses should consider conducting enhanced due diligence. 

OFSI consultation on ownership and control test in UK financial sanctions regulations 

OFSI has launched a call for evidence seeking industry views on how the ownership and control provisions in UK financial sanctions regulations are applied in practice, including how firms implement the regulations and the challenges they face. Firms, representative bodies and interested stakeholders are asked to share evidence and practical examples of: 

• how often "hypothetical control" is present in real financial sanctions cases;  
• the impact it has on compliance costs, legal risk and business decisions; and  
• whether existing legal concepts and typologies of control are helpful in applying ownership and control regulations.  

The call for evidence closes on 13 April 2026.  

Further information on the background and scope of the consultation is available on the OFSI blog. 

OFSI general licences and FAQs 

OFSI has issued the following: 

• General Licence INT/2026/8893924, which allows for the winding down of insurance policies written by Maritime Mutual entities and their subsidiaries before their designation. The general licence takes effect from 24 February 2026 and expires on 9 April 2026.
• General Licence INT/2026/8889196, which allows persons to wind down transactions involving PJSC Transneft to which they are a party. The general licence takes effect from 24 February 2026 and expires on 9 April 2026. 

OFSI has amended the following: 

• General Licence INT/2025/8031092, which allows for the continuation of business operations with Lukoil International Entities, has been extended. The general licence took effect from 27 November 2025 and now expires on 25 August 2026. FAQ 174 has been amended to reflect the new expiry date.
• General Licence INT/2025/5635700, which allows for the continuation of business operations with the relevant subsidiaries of Gazpromneft-Sakhalin LLC in relation to Russian oil exempt projects, has been amended to include any entity owned or controlled by PJSC Transneft following their designation.
• General Licence INT/2024/4761108, which allows persons to make use of the retail banking services of a designated credit or financial institution for personal remittances. The definitions of the general licence have been amended, a separate permission has been added, the cumulative limit of permitted payments has been increased from £50,000 to £55,000, and the reporting requirements have been amended. The general licence took effect on 22 May 2024 and expires on 23 February 2028.