Sanctions and export control | UK Regulatory Outlook October 2026

HM Treasury calls for annual frozen asset reports by end of November

As part of its annual review, HM Treasury requires that all persons holding or controlling funds or economic resources belonging to, owned, held or controlled by a designated person or entity report details of those frozen assets to the Office of Financial Sanctions Implementation (OFSI) by 30 November.

The obligation applies to anyone possessing this information, or who has previously reported frozen assets, and the relevant form needs to be submitted to the OFSI by the end-of-month deadline.

OFSI issues new general licences and clarifies delisting rules

The Office of Financial Sanctions Implementation has issued two new general licences, amended another, and added to its frequently asked questions (FAQs) list.

General Licence INT/2026/10050568, permits designated persons, or those acting on their behalf, to make payments to a UK bank account held by a landlord, managing agent or person acting on their behalf, covering ground rent, service charges and certain late payment fees relating to an eligible lease of a relevant property in England or Wales. The licence took effect from 12 October and expires on 11 October 2027.

General Licence INT/2026/11080040 permits the wind-down from transactions involving Zarubezhneft JSC or its subsidiaries, together with activities reasonably necessary to complete that process. The licence took effect from 8 October and expires on 21 November.

FAQ 205 confirms what happens to specific licences when a designated person is delisted. The FAQs also explains how OFSI will treat pending licence applications, and what happens if a person or entity is subsequently re-listed.

OFSI has also amended General Licence INT/2025/5635700, which permits the continuation of business operations with Gazpromneft-Sakhalin LLC and its subsidiaries, to the extent they relate to exempt projects. The Sakhalin-2 exemption has been extended and now expires on 31 December this year.

Export Control Joint Unit suspends control list classification advisory service

The Export Control Joint Unit (ECJU) and the Office of Trade Sanctions Implementation (OTSI) have published notice to exporters 2026/22, which announced the temporary suspension of the control list classification (CLC) service from 12 October, so that ECJU resources could be redirected to processing export licence applications with minimal delay.

The CLC service was introduced to help businesses assess their goods, software and technology against the relevant UK control lists.

ECJU is continuing to process CLC requests received before 12 October, though responses may take longer than usual. New CLC requests submitted during the pause will not be processed. Exporters affected should instead consider, in the meantime, self-assessing classification or seeking independent advice.