Sanctions and export control | UK Regulatory Outlook November 2025
Published on 26th November 2025
NCA issues amber alert on shadow fleet sanctions evasion | HMRC case study on export control civil enforcement
NCA issues amber alert on shadow fleet sanctions evasion
The National Crime Agency (NCA), Office of Financial Sanctions Implementation (OFSI) and Foreign Commonwealth & Development Office (FCDO) have jointly issued an amber alert to raise awareness of sanctions evasion involving commodities and financial transactions by networks and shadow fleets supporting sanctioned regimes including Russia, Iran and North Korea.
The alert is directed at helping maritime and financial institutions identify and prevent sanctions evasion involving sophisticated, state-backed networks that exploit opaque corporate structures and deceptive maritime practices. The use of shadow fleets commonly involves the use of older vessels with opaque ownership structures, which are routinely renamed and reflagged under permissive jurisdictions.
The alert provides typological characteristics and red flag indicators to help firms identify potential evasion activity. Firms in the regulated sector are reminded to submit suspicious activity reports through the NCA Portal if they identify indicative activity; any suspected frozen assets or financial sanctions breaches should be reported to OFSI.
HMRC case study on £1.1m export control civil enforcement
HM Revenue and Customs (HMRC) published a case study involving a £1,160,725.67 compound settlement from May 2025 for a breach of the Russia sanctions, the largest compound settlement it has concluded for a Russia sanctions offence.
The breach related to an unnamed UK exporter that exported goods to Russia in breach of The Russia (Sanctions) (EU Exit) Regulations 2019. The case study sets out the following key compliance lessons:
Exporting to third countries: UK companies exporting goods to third countries such as Central Asia and other regions must check whether the consignee, end-user or any other party receiving the goods is not a Russian-owned company, as Russian companies operate extensively in these regions. Supplying sanctioned goods to Russian companies operating outside of Russia is still a breach of UK sanctions.
Risk of being uninformed: Companies must stay informed of new sanctions measures; ignorance of sanctions is not a defence to sanctions breaches. Businesses should review their trading relationships when sanctions are updated and seek professional legal advice if they are uncertain of whether they are compliant with sanctions requirements.
Meaning of "connected with Russia": A person is "connected with" Russia under the sanctions regulations if they are an individual ordinarily resident or located in Russia, a legal entity incorporated under Russian law, or a legal entity domiciled in Russia. This includes Russian incorporated companies operating anywhere in the world, meaning UK businesses are prohibited from making certain goods, technology or software available to such entities, regardless of their physical location.
The prohibition of "making available" in regulations: Companies should be aware of the relevant regulations that prohibit making sanctioned goods, technology and software available for use in Russia or to persons connected with Russia (Regulation 25, 42, 46BN, 46L, 46N, 46Y, 46Z30, 46Z34). Additional prohibitions apply to making restricted goods and technology available for use in non-government controlled Ukrainian territory or to persons connected with such territory (Regulations 30D and 50).
OFSI general licences and FAQs
The new legal services general licence INT/2025/7323088 came into effect on 29 October 2025 (see details in our previous Regulatory Outlook). The general licence permits a UK legal firm or UK counsel who has provided legal advice to a person designated under the UK Autonomous Sanctions Regimes to receive payment.
OFSI has issued the following:
General Licence INT/2025/7895596, which permits the continuation of business operations with the Lukoil Bulgaria Entities. The general licence takes effect from 14 November 2025 and expires on 14 February 2026. FAQ 173 has been added to address continuing business operations with these entities.
FAQ 172 has been added, covering OFSI licencing for a UK financial institution to deal with or receive funds allocated to it by an International Central Securities Depository (ICSD) where corresponding ICSD funds held by the National Settlement Depository (NSD) have been seized and dealt with by the NSD.
OFSI has also amended the following:
General Licence INT/2024/5394840, which allows relevant Institutions to process payments from 2022, from or via a designated credit or financial institution, provided that the original sender and intended recipient are not designated persons. This general licence was due to expire on 6 November 2025 but has been extended to 7 November 2027. The definitions of a designated credit or financial institution and reporting conditions have also been amended.
FAQ 53 has been amended, covering the sanctions regimes are under the scope of the legal services general licence.
The following FAQs have been withdrawn:
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Regulatory law affects all businesses.
Osborne Clarke’s updated Regulatory Outlook provides you with high level summaries of important forthcoming regulatory developments to help in-house lawyers, compliance professionals and directors navigate the fast-moving business compliance landscape in the UK.
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