2025 saw the largest annual number of OFSI enforcement actions and a number of interesting developments to the UK sanctions landscape. We set out a summary of some of the key highlights below.

January

The year started with Parliamentary questions, during which the UK Economic Secretary announced that the Office of Financial Sanctions Implementation ("OFSI") had investigated and closed 388 cases since February 2022 and, as an indicator of the bumper year (by OFSI's metrics) of enforcement decisions to come, 318 open investigations into potential breaches of the UK's Russia sanctions.¹

February

Whilst much of 2025 focused on Russia sanctions, February saw a sanctioned UK charity director charged with an offence under the UK Counter-Terrorism Sanctions Regulations, for refusing or failing to provide OFSI with information about funds or economic resources. Following a trial in June, the individual was found guilty and given a suspended prison sentence.
February also saw OFSI publish the first in its series of sector-specific threat assessment reports, examining threats to UK financial sanctions compliance for the financial services industry. OFSI stated that the threat assessment report was intended to assist stakeholders with prioritisation as part of a risk-based approach to compliance.²

March

In March, OFSI announced its first civil monetary penalty of the year: a penalty in the amount of £465,000 issued against Herbert Smith Freehills CIS LLP Moscow ("HSF Moscow"). The penalty related to six payments made by HSF Moscow to designated banks in connection with the wind down of its operations in Russia.³  OFSI assessed the case as "serious" (as opposed to "most serious"), citing the seniority of staff who authorised the payments as an aggravating factor, and giving a voluntary disclosure discount of 50% to reflect the prompt and complete voluntary disclosure and co-operation.

April

The UK Government amended the Syria sanctions regime during March and April 2025 to reflect the fall of the Assad regime, removing various investment and financial services restrictions, and lifting asset freezes in relation to various Syrian banks, including the Central Bank of Syria.⁴

Two individuals were convicted in April 2025 at Southwark Crown Court in the UK's first criminal prosecution of Russian sanctions breaches. Both individuals, Russian nationals, were found guilty of breaching financial sanctions and money laundering and sentenced to 40 months imprisonment and 15 months imprisonment suspended for 15 months respectively.⁵ The prosecution was brought by the National Crime Agency ("NCA").

May

On 8 May 2025, OFSI announced its second civil monetary penalty of the year: £5,000 imposed on Svarog Shipping & Trading Company Limited, for failing to respond to a statutory request for information. This case highlighted the need for firms to ensure they have appropriate communication and monitoring systems in place to properly and promptly address requests for information from OFSI, including by appointing responsible personnel and maintaining up-to-date contact details.⁶

June

In June, the UK Solicitors Regulation Authority ("SRA") published a regulatory settlement agreement with Steptoe International (UK) LLP for self-reported breaches of the UK's Russia sanctions. The breaches related to failure to comply with licence conditions, and resulted in a public written rebuke and an order for Steptoe to pay the costs of the SRA's investigation, in the sum of £600.⁷

In a 5 June 2025 judgment (JP Morgan Securities PLC & Ors v VTB Bank PJSC [2025] EWHC 1368), the UK High Court granted anti-suit and anti-enforcement injunctions to JP Morgan in relation to proceedings issued against it in Russia in connection with the termination of several contracts with VTB after VTB's designation. VTB commenced proceedings in Russia in contravention of an English law and LCIA arbitration clause. The High Court granted the anti-suit and anti-enforcement injunctions against VTB on the basis that the claim pursued in Russia was vexatious and oppressive.⁸

July

On 29 July 2025, the Supreme Court handed down judgment in the combined appeals of Shvidler v Secretary of State for Foreign, Commonwealth and Development Affairs and Dalston Projects Ltd and others v Secretary of State for Transport ([2025] UKSC 30). The Supreme Court dismissed the appeals and upheld the legality of both the decision taken by the Foreign Secretary to designate Mr Shvidler, and the decision taken by the Transport Secretary to detain the superyacht "Phi". The Supreme Court (Lord Leggatt dissenting) held that the measures imposed were proportionate and lawful, and that the Government has a wide margin of discretion when it comes to foreign policy issues.⁹

On 31 July 2025, OFSI issued a civil monetary penalty of £300,000 on Markom Management Limited. The penalty was imposed under the UK's pre-Brexit Ukraine sanctions regulations in relation to a payment to a designated person, instructed by senior management of Markom. In this case, although OFSI noted that Markom had submitted a materially complete initial disclosure to OFSI, OFSI considered that the disclosure did not meet was not considered to have met the criteria for a voluntary discount reduction.¹⁰

Also in July, OFSI launched a public consultation on proposed changes to the civil enforcement process for financial sanctions. You can read about the changes proposed in the consultation in our previous blog post here.

August

August was relatively quiet on the UK sanctions front although practitioners were faced with contemplating the implications of two High Court decisions handed down on 31 July 2025:

In Tonzip Maritime Ltd v 2Rivers Pte Ltd ([2025] EWHC 2036 (Comm), the shipowner refused to load cargo after a sanctions screening check identified the shipper, a Russian company, as a potential sanctions risk due to a previous association to a designated person. The charterer challenged the refusal and purported to cancel the charterparty. The Court ruled in favour of the charterer, concluding that the shipowner had not made an objectively reasonable decision based on the information available at the time, and that the sanctions clause in the charterparty was to be narrowly construed.¹¹

LLC Eurochem North-West-2 and another v Société Générale S.A. and others et al ([2025] EWHC 1938 (Comm)) was primarily a case on the interpretation of EU sanctions, however the judgment did have relevance to UK sanctions. In particular, the factual findings of the Court are relevant to an assessment of ownership of Eurochem AG for the purposes of UK sanctions.¹²

September

September brought two more OFSI enforcement matters. First, a public disclosure was issued on a UK bank for breaching the UK's Counter-Terrorism sanctions regulations. The breaches occurred due to an 8-day delay in restricting access to an account held by a designated person. The designated person withdrew £200 in cash and made a purchase of £8.99 in the intervening period. OFSI had in this case forewarned the bank that a suspected customer of the bank was due to be designated the following day but did not specify which customer. OFSI considered this an aggravating factor in the context of the time taken to restrict the customer's account.¹³

At the end of September, OFSI issued a civil monetary penalty in the amount of £152,750 on Colorcon Limited, for breaches of the UK's Russia sanctions. The breaches were payments made to non-designated employees and service providers of Colorcon's Moscow office who held accounts at designated banks. OFSI criticised the 4-month delay between Colorcon becoming aware of the breaches and making an initial disclosure to OFSI, and consequently only gave a 35% voluntary disclosure discount to the penalty.¹⁴

October

On 1 October 2025, the UK reimposed the UN's sanctions on Iran following the end of the "snapback" process which was triggered by the E3 in August due to Iran's non-performance of its commitments under the Joint Comprehensive Plan of Action.¹⁵  Whilst the UK has reinstated UN-mandated trade controls and reintroduced asset freezing measures (including UN-mandated designations and EU designations), so far the UK has not yet fully implemented the EU export and import controls and services restrictions against Iran which previously applied pre-Brexit.

On 15 October 2025, the UK government designated Russian oil giants Rosneft and Lukoil, and Indian refinery Nayara Energy for its dealings in Russian oil.

Also in mid-October, OFSI published its Annual Review for 2024-2025. The Review highlighted that £37 billion worth of assets has been reported to OFSI as frozen, and that OFSI had increased its operational capacity in the face of continued pressure to make active use of sanctions. It also cautioned that the majority of suspected breach cases recorded by OFSI in 2024-2025 related to the financial services sector and that many open cases are expected to reach decision points during 2025-2026.¹⁶

November

In November, a London art gallery and a London-based art logistics company were charged with breaching the UK's Russia sanctions regulations by making luxury goods available to a person connected with Russia. The case will be heard at Southwark Crown Court.

The NCA published details of 'Operation Destabilise', its complex investigation which exposed a billion-dollar money laundering network that purchased a bank in Kyrgyzstan to facilitate sanctions evasion and payments.¹⁷

December

December has, so far, seen the Office of Trade Sanctions Implementation ("OTSI") publish its first annual report, which highlighted its 82-working-day turnaround time for licence applications (of which 12 were granted out of the 60 licence applications received), and the 144 reports or referrals of potential breaches of trade sanctions. Whilst it has not yet issued any civil monetary penalties, it does have investigations underway and expects to provide an update on its enforcement action in its next annual report.¹⁸

The UK Government has also taken steps to enable the donation of £2.5 billion in proceeds from the sale of Chelsea Football Club to benefit the people of Ukraine. Prime Minister Keir Starmer warned that the government is prepared to enforce Abramovich's commitment to donate the funds through the courts if the payment isn't forthcoming.¹⁹

Our 2026 prediction…

Assuming no further major geo-political developments that result in another Russia-scale sanctions programme, we expect that the number of enforcement cases will continue to rise and that the financial services industry continues to be a focus. We also await the outcome of OFSI's consultation on changes to its enforcement process, including the potential doubling of statutory maximum penalties and the hotly anticipated settlement scheme. In the meantime, if you haven't had your sanctions fill, you can read more of our thoughts on the recent UK sanctions enforcement trends here.
 

¹ https://questions-statements.parliament.uk/written-questions/detail/2025-01-17/24637
² https://www.gov.uk/government/publications/sanctions-compliance-in-the-financial-services-sector-threat-assessment
³ https://assets.publishing.service.gov.uk/media/67dae19a1a60f79643028472/200325_HSF_PENALTY_NOTICE.pdf
⁴ https://www.gov.uk/government/news/uk-bolsters-support-for-syrian-people-by-amending-syria-sanctions
⁵ https://www.cps.gov.uk/cps/news/sentencing-first-ever-uk-prosecution-russian-sanction-breaches
⁶ https://assets.publishing.service.gov.uk/media/681c69ff3f1c73824ee3e56e/Publication_Notice_-_Svarog.pdf
⁷ https://www.sra.org.uk/consumers/solicitor-check/635838/
⁸ https://www.bailii.org/ew/cases/EWHC/Comm/2025/1368.html
⁹ https://supremecourt.uk/uploads/uksc_2024_0045_0055_judgment_b490db4480.pdf
¹⁰ https://assets.publishing.service.gov.uk/media/688b92af6c7eb66caea94df3/Penalty_Publication_Notice_-_MML.pdf
¹¹ https://www.bailii.org/ew/cases/EWHC/Comm/2025/2036.html
¹² https://www.bailii.org/ew/cases/EWHC/Comm/2025/1938.html
_¹³ https://assets.publishing.service.gov.uk/media/68beb534de0987fe84e0dd0f/VBL_Disclosure_Notice_08SEPT2025.pdf
¹⁴ https://assets.publishing.service.gov.uk/media/68db9df2ef1c2f72bc1e4bf0/Colorcon_Penalty_Notice.pdf
¹⁵ https://www.gov.uk/government/news/uk-reimposes-un-sanctions-on-iran
¹⁶ https://assets.publishing.service.gov.uk/media/68ef7ec68427701993d5e0d9/OFSI_Annual_Review_2024-25.pdf
¹⁷ https://www.nationalcrimeagency.gov.uk/news/operation-destabilise-nca-exposes-billion-dollar-money-laundering-network-that-purchased-bank-to-fund-russian-war-effort
¹⁸ https://assets.publishing.service.gov.uk/media/6931697c4bedc0e76230406b/OTSI_One_Year_Update.pdf
¹⁹ https://www.gov.uk/government/news/government-gives-abramovich-final-chance-to-pay-25-billion-to-ukraine-or-risk-court-action