UK Weekly Sanctions Update - Week of November 3, 2025

In this weekly update, we summarise the most notable updates in the UK sanctions world.

RUSSIA SANCTIONS

• OFSI amends General Licence relating to payments made between third parties and sanctioned financial institutions in 2022: On November 5, 2025, OFSI amended General Licence INT/2024/5394840, which authorises the processing of certain payments made in 2022 that have been processed by a sanctioned credit or financial institution at some point in the chain of payments. Among other things, the General Licence was extended to November 7, 2027, and its reporting conditions were updated. (https://assets.publishing.service.gov.uk/media/690b76669456634d9795fe48/INT_2024_5394840_GL.pdf)
• OTSI publishes guidance for the freight and shipping sector on countering sanctions evasion: On November 3, 2025, the Office of Trade Sanctions Implementation (“OTSI”) published new guidance on countering Russian sanctions evasion targeted at businesses operating in the freight and shipping sectors. The guidance contains: (i) information on the range of goods at heightened risk of being diverted to Russia; (ii) suggestions for compliance best practice and enhanced due diligence procedures; (iii) red flag indicators of potential sanctions evasion via circumvention; and (iv) additional resources to aid businesses in managing their risk and meeting their compliance obligations. (https://www.gov.uk/government/publications/countering-sanctions-evasion-guidance-for-freight-and-shipping/countering-russian-sanctions-evasion-guidance-for-the-freight-and-shipping-sector)
• HMRC publishes case study on £1.1 million compound settlement for breach of Russia sanctions: On November 3, 2025, HM Revenue and Customs published a case study under which a UK exporter paid a £1.1 million compound settlement for making goods available to Russia in breach of UK sanctions. The case study highlighted the risks of exporting to third countries and of being informed of trade sanctions. The case study also provided guidance on the meaning of ‘connected with Russia’ and the scope of the ‘making available’ prohibitions under the UK Russia regulations. (https://www.gov.uk/government/case-studies/11-million-compound-settlement-for-sanctions-breach)

IRAN SANCTIONS

• UK Government amends statutory guidance for the Iran nuclear regime: On November 6, 2025, the UK Government amended its statutory guidance for the Iran nuclear regime to reflect the Iran (Sanctions) (Nuclear) (EU Exit) (Amendment) Regulations 2025, which implements the UK's UN obligations post 'Snapback'. (https://www.gov.uk/government/publications/iran-nuclear-sanctions-guidance/iran-nuclear-sanctions-guidance)
• UK Government amends one entry on the UK sanctions list under the Iran regime: On November 3, 2025, the UK Government amended the entry for Ali Aliakbar Ansari on the UK sanctions list under the Iran regime. (https://assets.publishing.service.gov.uk/media/6908b764c0dc8f1248417588/Notice_Iran_031125.pdf)

ISIL (DA’ESH) AND AL-QAIDA SANCTIONS

• UK Government removes two entries under the ISIL (Da’esh) and Al-Qaida sanctions regime: On November 7, 2025, the UK Government removed the entries for Ahmad Hussain Al-Sharaa and Anas Hasan Khattab under the ISIL (Da’esh) and Al-Qaida sanctions regime, reflecting UN Security Council Resolution 2799 (2025). (https://assets.publishing.service.gov.uk/media/690dc49547ad122f8546279f/Notice_ISIL__Da_esh__and_Al-Qaida_071125.pdf)

COUNTER-TERRORISM SANCTIONS

• UK adds two entries to the UK sanctions list under the counter-terrorism regime: On November 6, 2025, the UK Government added Kieren James Gallagher and the New Irish Republican Army to the UK sanctions list under the counter-terrorism regime. According to the UK Government, these measures are the second Treasury-led domestic counter-terrorism action to target Northern Ireland-related terrorism. (https://assets.publishing.service.gov.uk/media/690c6ddeb5e5a06aefd46ae1/Notice_Counter_Terrorism__Domestic
  __061125.pdf; https://www.gov.uk/government/news/new-ira-and-suspected-terror-facilitator-sanctioned)

DPRK SANCTIONS

• UK updates North Korea trade sanctions guidance: On November 5, 2025, the UK Government amended its statutory guidance for the Democratic People’s Republic of Korea regime. Among other things, guidance on the specific grounds for granting trade licences for sanctions goods has been updated in relation to the export, making available, supply or delivery of luxury goods for the purposes of news gathering for use by independent new mediate organisations. (https://www.gov.uk/government/publications/democratic-peoples-republic-of-korea-sanctions-guidance/democratic-peoples-republic-of-korea-sanctions-guidance)

OTHER SANCTIONS

• UK Government publishes Notice to Exporters advising of upcoming updates to UK strategic export controls: On November 7, 2025, the ECJU published Notice to Exporters 2025/29 providing advance notice of an upcoming statutory instrument – The Export Control (Amendment) (No.2) Regulations 2025. It is anticipates that the regulations will be laid in November and come into force in December, with the intention to align the UK’s export control framework with its international commitments and recent EU regulatory changes. (https://www.gov.uk/government/publications/notice-to-exporters-202529-the-export-control-amendment-no2-regulations-2025/nte-202529-the-export-control-amendment-no2-regulations-2025)

UK Government publishes new sanctions enforcement page: On November 3, 2025, the UK Government published a new webpage that brings together sanctions enforcement information from across HM Government, including penalty notices, annual reviews, case studies and key lessons for industry. This is intended to help industry learn from remedial action, following a cross-government review of sanctions implementation and enforcement. (https://www.gov.uk/government/collections/sanctions-enforcement-action)

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