Sanctions and export control | UK Regulatory Outlook May 2025

UK announces new wide-ranging sanctions on Russia

The Foreign, Commonwealth & Development Office announced further sanctions on Russia following a wave of Russian drone attacks against Ukraine.

The sanctions package targets entities supporting Russia's military operations, energy exports and supply chain of weapons systems, and 46 financial institutions believed to be funding the Russian war effort.

The Office of Financial Sanctions Implementation (OFSI) has issued two general licences in relation to the new designations:

• General Licence INT/2025/6279615: which allows for persons to make insurance premiums payments to the Deposit Insurance Agency of Russia. This general licence takes effect from 20 May 2025 and is of indefinite duration.
• General Licence INT/2025/6275812: which permits wind down transactions down involving St Petersburg Currency Exchange and Non-bank Credit Organization Joint-Stock Company Petersburg Settlement Center. This general licence takes effect from 20 May 2025 and expires on 19 June 2025.

OFSI fines shipping company for breach of Russia sanctions

OFSI fined Svarog Shipping & Trading Company Limited, a UK-registered company, £5,000 for an information offence – the first of its kind to be issued by OFSI.

Svarog failed to respond within the required timeframe to a statutory Request for Information (RFI) made by OFSI, and failed to provide a reasonable excuse. In those circumstances, OFSI has the power to impose a penalty in respect of the information offence. Having been informed of OFSI’s intention to impose a monetary penalty and invited to make representations, Svarog made no representations and did not seek a review of OFSI’s decision.

The case was assessed to be "serious". Aggravating factors included Svarog's failure to address the RFI until after the deadline had passed, and the fact that it operated in a sector (maritime oil shipment) with elevated exposure to sanctions, which ought to have made the company more vigilant to OFSI's request.

This case highlights the importance of firms and individuals responding in a timely manner to OFSI RFIs. OFSI has published a "lessons learned" blog post which provides a helpful overview of RFIs, a brief summary of the Svarog case, and the key compliance lessons that industry can take away.

Export Control (Amendment) Regulations 2025 come into force

The government introduced the Export Control (Amendment) Regulations 2025 to Parliament on 29 April 2025, amending the Export Control Order 2008 (2008 Order) and Council Regulation (EC) No 428/2009.

The regulations, which came into force on 20 May 2025, amend:

• the fines which may be imposed for certain offences set out in Part 6 of the 2008 Order;
• Schedule 2 (military goods, software and technology) to the 2008 Order;
• Schedule 3 (dual-use goods, software and technology) to the 2008 Order; and
• Annex I (dual-use goods, software and technology) to the assimilated Dual-Use Regulation.

Specifically, the maximum level of fine that may be imposed under the 2008 Order for certain offences has increased from £1,000 to £2,500; new items have been added to the military goods and dual-use control lists alongside amended definitions and associated technical notes.

See the notice to exporters for further information.

New approval form for exporting controlled goods

The Export Control Joint Unit (ECJU) of the Department for Business and Trade has launched a new MOD security approval form 680 (F680) on the service "apply to export controlled goods" (previously known as LITE).

Exporters will be contacted by the ECJU when they are eligible to apply for F680s. The ECJU intends for all F680 applications to be transitioned to the new service from the current system, SPIRE, in the coming weeks. Further updates can be found on the notice to exporters page.

OFSI general licences

OFSI has extended the following general licences:

• General Licence INT/2022/1834876: which permits interim managers and trustees of a charity to act as a receiver and manager with respect to certain property and affairs of the charity. The general licence was set to expire on 30 May 2025 but has been extended to 30 May 2028.
• General Licence INT/2023/3263556: which authorises payments concerning insolvency proceedings of GTLK companies and its subsidiaries. The general licence was set to expire on 31 July 2025 but has been extended to 31 July 2030.
• General Licence INT/2022/1678476: which authorises winding down, basic needs and insolvency related payments to be made in relation to Amsterdam Trade Bank N.V (ATB). The licence has also been amended to allow bankruptcy trustees and any other insolvency practitioner to make, receive, or process any payments, exercise all rights, or take any other actions in connection with insolvency proceedings in relation with ATB, and/or the fulfilment of their statutory functions. The general licence expired on 12 May 2025 but has been extended to 12 May 2030.