Sanctions and export control | UK Regulatory Outlook September 2025

OFSI issues disclosure notice for breach of UK-Counter Terrorism Sanctions 

The Office of Financial Sanctions Implementation (OFSI) published a disclosure notice against a UK bank for a breach of the Counter-Terrorism Regulations 2019.  

The breaches occurred due to the bank's delay in restricting access to a customer's account for eight days following designation, during which time a designated person had full access to their funds. In permitting the designated person to withdraw cash and complete a transaction, the bank made funds directly available to a designated person.  

OFSI assessed the breach as "moderately severe", and did not consider it sufficiently serious to impose a monetary penalty. However, a number of aggravating factors were considered by OFSI in reaching the decision to publish the disclosure: 

• The bank had been warned that a suspected customer was due to be designated, which should have made it "especially vigilant" to the designation.
• The bank made funds directly available to the designated person and a purchase was processed on their account.
• There was an eight day delay between designation and restricting the account, during which the designated person had full access to their credit card.
• The bank is a Financial Conduct Authority regulated firm, and is therefore expected to have "significant awareness and understanding of sanctions risks", in addition to sufficient financial crime controls. 

The notice highlighted the following compliance lessons for the financial industry: 

• Firms must ensure that sanctions screening processes are sufficiently robust to enable them to act swiftly on designations and develop contingency plans to ensure business continuity and prevent delays in response to designations.
• Companies should exercise particular vigilance if they receive a notification form OFSI that a suspected customer may be designated in the near future.
• OFSI values voluntary disclosure of sanctions breaches. This may be considered a mitigating factor. 

Read more about OFSI's disclosure power in this Insight.  

OFSI fines UK financial services company £300,000 for breach of Russia sanctions 

OFSI announced it has issued a £300,000 monetary penalty against a UK-registered company for a breach of UK sanctions against Russia.  

The breach related to a payment of £416,590.92, instructed by the company, to be made directly to a designated person subject to an asset freeze. Having been informed of OFSI’s intention to impose a monetary penalty, the company submitted additional material, upon which OFSI revised the penalty amount from £400,000 down to £300,000. 

The case was assessed to be "serious". Aggravating factors included the amount of funds transferred, which OFSI considers to be a "high value breach", and the company's sanctions policies and controls, which were considered inadequate because there were no controls to manage the sanctions risk of informal transnational working practices (the context within which the breach took place). 

OFSI highlighted the following key compliance lessons for industry: 

• All firms, regardless of their size, should take appropriate steps to understand and address their exposure to sanctions risks.
• Firms should have adequate sanctions processes to ensure compliance. OFSI may not consider the existence of sanctions policies and processes to be a mitigating factor if they are not fit for purpose.
• All firms should have systems and controls in place to enable them to promptly identify and report suspected breaches of financial sanctions to OFSI. Firms which make voluntary disclosures in serious cases are eligible for a discount of up to 50%. 

Read the press release. 

Annual frozen asset reporting exercise  

As part of its annual review, HM Treasury requests that all persons holding or controlling funds or economic resources belonging to, owned, held or controlled by a designated person/entity to report details of those frozen assets. 

Anyone possessing this information or who have previously reported frozen assets must complete the form and submit it to OFSI by 30 November 2025. 

OFSI general licences 

OFSI has published three general licence FAQs on General licence INT/2025/6641960, which allows non-designated persons who have made investments through designated brokers to transfer their funds to a non-designated broker. The general licence came into effect on 18 July 2025 and is of indefinite duration. 

OFSI has also amended the following general licences to include the Global Irregular Migration and Trafficking in Persons Sanctions Regulations 2025 as one of the applicable regimes: 

• General licence INT/2024/4888228 – which allows for payments to Statutory Auditors for a Statutory Audit from, or on behalf of, a designated person. The general licence came into effect on 27 June 2024 and is of indefinite duration.
• General licence INT/2024/4907888– which allows for payments to visa application services providers from, or on behalf of, a designated person. The general licence came into effect on 3 July 2024 and is of indefinite duration.
• General licence INT/2022/2009156 - which allows for payments to UK insurance companies. The general licence came into effect on 22 July 2022 and is of indefinite duration. 

End-user and stockist undertaking form guidance 

The UK Export Control Joint Unit published guidance on its end-user and stockist undertaking form. 

From July 2025, the form should be used for all exports, by the end-user or stockist of the items which are being exported, if the UK exporter is applying for: 

• a standard individual export licence (SIEL);
• a standard individual trade control licence; or
• a licence to provide technical assistance. 

The completed form is to be submitted as part of the licencing application and must be completed even if the items: 

• are being shipped via a consignee;
• will be incorporated by the end-user; or
• will be held as stock.  

The licence application must be submitted by the UK exporter within six months of the date the end-user and stockist undertaking form is signed.