Key developments at the intersection of security and commerce.
By: Michael Ruck, Rosie Naylor, Petr Bartoš, and Laura Scott
On 21 July 2025, the UK Office for Financial Sanctions Implementation (OFSI) released a detailed threat assessment focused on the crypto-asset sector’s vulnerability to sanctions breaches (the Assessment). This Assessment sends a clear warning to UK crypto firms: sanctions compliance is not optional, and enforcement is tightening.
Read MoreBy: Michael Ruck, Rosie Naylor, Petr Bartoš, and Laura Scott
On 18 July 2025, the European Union adopted its 18th sanctions package targeting Russia in response to its continued aggression in Ukraine (the Package). This wide-ranging set of measures builds on previous rounds of sanctions and aims to increase pressure on Russia by targeting its energy revenue, banking sector, military capabilities, and circumvention tactics. The Package also includes symbolic steps to hold Russia accountable for crimes against Ukrainian children and cultural heritage.
Read MoreBy: Michael Ruck, Rosie Naylor, Petr Bartoš, and Laura Scott
On 22 July 2025, the UK Office of Financial Sanctions Implementation (OFSI) launched a significant consultation on proposed reforms to its civil enforcement framework (the Consultation). These reforms – currently open for consultation until 13 October 2025 – could reshape how sanctions breaches are investigated, penalised and resolved. This marks a decisive shift away from OFSI’s traditionally cautious approach, and signals that the UK is moving toward a more assertive, US-style sanctions enforcement model.
Read MoreBy: Michael E. Ruck, Rosie Naylor, Petr Bartoš, and Laura Scott
On 14 July 2025, the United Kingdom’s Foreign, Commonwealth and Development Office released important sanctions guidance aimed specifically at non-UK companies operating outside the United Kingdom, with a special focus on Russia-related sanctions (the Guidance). The Guidance also includes tailored advice for businesses active in Kazakhstan, Uzbekistan, Kyrgyzstan, Georgia and Armenia, countries that are frequently used as transit points to circumvent Russian sanctions.
Read MoreBy: Michael E. Ruck, Rosie Naylor, Petr Bartoš, and Laura Scott
On 18 June 2025, the UK Office for Financial Sanctions Implementation (OFSI) released a Threat Assessment (the Assessment) targeting Art Market Participants (AMPs) and High-Value Dealers (HVDs). This follows new rules from 14 May 2025, which make AMPs and HVDs legally responsible for reporting sanctions breaches involving designated persons (DPs).
Read MoreBy: Michael Ruck, Rosie Naylor, Petr Bartos, and Laura Scott
On 15 May 2025, the UK government published a policy paper summarising findings from a cross-government review of sanctions implementation and enforcement. The aim of the review was to identify further steps to improve and facilitate compliance, increase and harness deterrence, and invigorate the cross-government toolkit.
Read MoreBy: Jeffrey Orenstein, Guillermo Christensen, Steven Hill, David Allman, Nate Bolin, and Brian Hopkins
On 23 May 2025, the United States provided broad sanctions relief to Syria and the new Government of Syria under President Ahmed al-Sharaa. While speaking at an investment forum in Riyadh, President Trump announced his intentions to lift sanctions on Syria, stating that sanctions relief will “give them a chance at greatness.”
By: Michael Ruck, Rosie Naylor, and Laura Scott
In its first-ever threat assessment of the UK legal sector, the UK’s Office of Financial Sanctions Implementation (OFSI) has highlighted key findings surrounding suspected sanctions breaches involving UK legal services providers since February 2022 (the Assessment).
Read MoreBy: Steven F. Hill, Guillermo S. Christensen, Jeff Orenstein, and Brian J. Hopkins
On 24 March 2025, the White House issued an Executive Order threatening to impose a 25% tariff on all goods imported into the United States from any country that imports Venezuelan oil directly or indirectly through third parties. Effective on or after 2 April 2025, the tariff is in response to alleged actions of Venezuela’s Maduro government, in particular sending members of the Tren de Aragua gang (designated a foreign terrorist organization) and other criminals into the United States and its involvement in kidnapping and violent attacks including the assassination of a Venezuelan opposition figure.
Read MoreBy: Laura Scott, Petr Bartos, and Michael Ruck
On 24 February 2025, the European Union adopted the 16th Russia sanctions package.
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