Sanctions and export control | UK Regulatory Outlook October 2025

Move to single list for UK sanctions designations 

The Foreign, Commonwealth, and Development Office, Office of Financial Sanction Implementation (OFSI) and Office of Trade Sanction Implementation (OTSI) have jointly announced the closure of the OFSI Consolidated List of Asset Freeze Targets. 

The UK currently publishes two sanctions lists – the UK Sanctions List, which lists designated persons, entities and ships, and the OFSI Consolidated List, which provides information related to asset freezes and investment ban targets across all UK financial sanctions regimes.  

The move is in response to industry feedback, following a cross-government review of sanctions implementation and enforcement, which noted that a single sanctions list would remove duplication of effort and simplify the screening process for designated persons. 

From 28 January 2026, the UK Sanctions List will be the only source for all UK sanctions designations. Organisations are advised to prepare their systems in advance of the closure of the OFSI Consolidated List, by switching to the UK Sanctions List as their primary source of designations data as soon as possible.  

Currently, designation updates are only published for financial sanctions designations, from January 2026, designation updates will also be published for all types of sanctions designations. See official guidance which has been published to help organisations prepare for the change. 

OFSI fines pharmaceutical firm £152,750 for breaches of Russia financial sanctions 

OFSI announced it has issued £152,750 monetary penalty against Colorcon Limited, a pharmaceutical industry supplier and UK-registered subsidiary of Colorcon Inc. 

The fine relates to payments made by Colorcon's Moscow office to its Russian employees and service providers. While the employees were not designated as sanctions targets, their banks were designated, meaning Colorcon breached financial sanctions by paying into accounts at the sanctioned banks. 

OFSI assessed the breach as "serious". Aggravating factors included Colorcon's status as a global company with an established presence in Russia that had "significant awareness" of sanctions risk but failed to take reasonable care. It also noted the repeated and persistent nature of the errors made by Colorcon in failing to identify multiple payments to accounts held at designated banks over an extended period (payments were made between March and December 2022). 

Read more about the key takeaways for industry in our dedicated Insight. 

OTSI publishes case study on trade sanctions breach detection 

OTSI has published a case study highlighting the importance of good due diligence in preventing breaches of trade sanctions regulations.  

The case study relates to a number of suspected breach reports from the UK branch of a multinational bank received by OTSI between April and June 2025, concerning the trade of a sanctioned product from Russia to a third country. The UK branch was acting as an intermediary in the transaction, as payment for the prohibited goods was routed through the bank. The bank, which is subject to UK sanctions regulations, performed enhanced due diligence checks following trade sanctions concerns, and did not process the payments.  

Following an internal investigation, the bank self-reported to OTSI, which concluded that there had not been a breach of trade sanctions by the UK branch of the bank, as the payments were ultimately not processed.  

Although the case study comes from the financial sector, the following key takeaways are of use to all businesses: 

• Adopt a risk-based approach to due diligence, ensure an understanding of how UK sanctions prohibitions impact the financial sector and use compliance lessons to improve awareness of sanctions evasion.
• Conduct regular enhanced due diligence on clients and transactions involving high-risk jurisdictions, particularly when there are changes in transactional patterns.  
• Understand the specific UK obligations within multinational corporate structures, particularly where requests and transactions originate from the wider corporate group.  
• Develop and maintain internal screening procedures necessary to identify transactions that may be in breach of UK trade sanctions regulations.  
• Implement safeguards that enable payments to be declined or stopped before they are made.  
• Ensure an understanding of the mandatory reporting requirements for regulated sectors, and the benefits of making voluntary disclosures.  
• Where necessary, use OTSI’s online reporting tool to promptly report potential breaches. 

OFSI annual review highlights Russia sanctions as a priority  

OFSI has published its annual review for 2024-25, reflecting on the progress and achievements of the regulator in ensuring compliance with financial sanctions.  

The report notes that the implementation and enforcement of Russia sanctions remains a priority, and the £28.7 billion worth of Russian assets frozen by UK sanctions since February 2022 highlights the impact of their work in stopping Russia from funding its invasion of Ukraine.  

OFSI remains committed to robust sanctions enforcement, having issued approximately £500,000 of penalties against firms and 57 enforcement actions, not including actions not made public, such as the issuance of warning letters and referrals to regulators. As of April 2025, OFSI has a total of 240 active cases under investigation, and expects to reach a decision on many of these in 2025-26.  

To support OFSI's shift to a proactive enforcement and compliance approach, a new, dedicated compliance enforcement team was established in 2024-25. The report states that the new team, responsible for reviewing, investigating and enforcing breaches of specific and general licences, has enabled OFSI to address underreporting and significantly reduced response times for licence-related enforcement action. 

Looking ahead, OFSI committed to refreshing its strategy, to support industry and help implement government policy strategies, with further information expected to be published in due course.  

Updated HM Treasury advisory notice on money laundering and terrorist financing controls in high-risk third countries 

HM Treasury has issued an updated advisory notice regarding the risks posed by jurisdictions with unsatisfactory money laundering and terrorist financing controls.  

This is in response to the publication of the Financial Action Task Force's (FATF) October update to its lists of jurisdictions identified as having strategic deficiencies in their anti-money laundering and counter-terrorist financing regimes, of jurisdictions "under increased monitoring" and high-risk jurisdictions "subject to a call for action" 

Burkina Faso, Mozambique, Nigeria and South Africa have been removed from the increased monitoring list. Jurisdictions under the "grey list" for increased monitoring include Algeria, Kenya, Vietnam, the Virgin Islands and Yemen. 

OTSI updates licensing platform for trade services 

OTSI has announced the introduction of a new "save and return" feature, enabling businesses to save their progress on an application when applying for trade licences online. The GOV.UK One login has also been enabled for users to sign in to OTSI's trade sanctions licensing service, with additional security features to help protect personal information.  

OFSI enforcement processes consultation closes 

The OFSI's public consultation on improving civil enforcement processes for financial sanctions closed on 13 October. The consultation sought views on how its current enforcement processes can be reformed, with the aim of ensuring their continued effectiveness, proportionality and transparency.  

OFSI has indicated that responses received will inform future reforms. We will report on the outcome once it has ben published. 

OFSI updates guidance on Russia sanctions amendments and exceptions  

The UK government has updated its guidance on the Russia (Sanctions) (EU Exit) Regulations 2019. Individuals may now: 

• Look up amendments to the Russia sanctions regulations; and
• Look up exceptions to trade and transport sanctions. 

OFSI general licences and FAQs 

OFSI has issued the following new general licences: 

• General Licence INT/2025/7323088, which 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 from that designated person, provided that the terms of the general licence are met. The general licence will take effect on 29 October and expires on 28 April 2026.
• General Licence INT/2025/7328184, which allows a revenue authority to make permitted payments to frozen UK bank accounts of UK designated persons. A revenue authority may also set off the amount of any permitted payment against any liability of the designated person to pay an amount to that revenue authority. The general licence came into effect on 26 September and is of indefinite duration. 

OFSI has also amended the following general licences: 

• General Licence INT/2022/2104808, which permits banks to take payment of bank fees from frozen accounts. The reference to frozen accounts has been removed from Permissions 4 to clarify that banks may take payment for service fees from any of a designated person's accounts. Service fees may also include any charges relating to payments made under the Required Payments Exception or the Asset-Freeze Exception. The general licence is of indefinite duration.
• General Licence INT/2023/3179120, which allows UK designated persons to make permitted payments to water companies from a frozen UK bank account and water companies to make return overpayments to frozen bank accounts. The reference to frozen accounts has been removed as per above. The definition of a designated person and reporting conditions have been updated, pursuant to the UK Autonomous Sanctions Regulations listed in annex 1 of the general licence, which is of indefinite duration.
• General Licence INT/2022/2300292, which permits payment to gas and electricity companies by UK Designated persons who own or rent properties in the UK. The reference to frozen accounts has been removed as per above, and the reporting conditions and annex I has been updated. The general licence is of indefinite duration. 

OFSI has published new FAQs, Q165-167, covering water, utility and banking bills and fees, as well as Q170-171, covering the newly published Legal Services General Licence INT/2025/7323088. 

General trade licence updates 

The Export Control Joint Unit has extended General Trade Licence NTE 2025/27, which permits: 

• the transfer of technology of business enterprise software and technology;
• the making available of business enterprise software and technology; and
• ancillary services relating to business enterprise software and technology. 

The licence was due to expire on 20 October; it has been extended to allow firms additional time for completing licensing processes to avoid any disruption in the use of sanctioned software and technology. The extended general licence came into effect on 16 October 2025 and expires on 17 April 2026.  

All published notices can be viewed on the notices to exporters collection page.