Monthly Sanctions Update (October 2025)

KEY DEVELOPMENTS

• Sanctions on Iran reinstated due to a snapback mechanism incorporated in the Joint Comprehensive Plan of Action (JCPOA).
• 71 people / entities were designated on 29 September 2025.
• New designations on cryptoasset companies related to Russia and companies importing Russian-origin crude oil.
• New Foreign Influence Registration Scheme introduced in July 2025.
• July 2025 judgment: Tonzip Maritime Ltd v 2Rivers PTE Ltd [2025] EWHC 2036 (Comm); appeal outstanding.
• OFSI consultation window shut on 13 October 2025; reforms to be expected.
• UK Sanctions List to become the single authoritative source for UK designations.

IRAN

29 September 2025: UN sanctions on Iran reinstated via snapback mechanism of the JCPOA, the 2015 Iran nuclear deal. This was reinstated following Iran’s repeated breaches of its commitments to the JCPOA, with foreign ministers of the E3 citing Tehran’s refusal to authorise International Atomic Energy Agency (IAEA) inspectors to access Iran’s nuclear sites and the failure to produce a record of Iran’s stockpile of high-enriched uranium as a trigger for the snapback.

29 September 2025: UK issued 71 designations under Iran (Sanctions) (Nuclear) (EU Exit) Regulations 2019 against entities and individuals said to be or have been involved with nuclear weapon development and proliferation in, or for use in, Iran.

RUSSIA

August 2025: UK announced designations on entities and persons operating in the crypto sector. This follows on from the OFSI’s findings that there is an 80-90% probability that cryptoasset firms in the UK have been exposed to Garantex since its 2022 designation. OFSI also reports that it is likely that UK firms have been enabling transfers to Iranian cryptoasset firms linked to designated persons and entities.

12 September 2025: UK introduced 100 new sanctions targeted at Russia’s military sector and shadow fleets. Those sanctioned supply electronics, chemicals, and explosives used to build weapons and missiles.

3 October 2025: The Council for the EU decided to prolong sanctions against those involved in ‘destabilising actions abroad’ by a further year, until 9 October 2026. There was a specific emphasis on Foreign Information Manipulation and Interference (FIMI) against the EU and its partners. The continuation of these restrictive measures is a result of observed behaviour by Russia such as ‘cyber-attacks, acts of sabotage, disruption of critical infrastructure, physical attacks, information manipulation and interference, and other covert or coercive actions’ (Consilium).

24 April 2025: The Russia (Sanctions) (EU Exit) (Amendment) Regulations 2025 took effect. These regulations amended the Russia (Sanctions) (EU Exit) Regulations 2019 and introduced new trade prohibitions and expanded restrictions on exports, imports, and related services in sectors including:

• Chemicals, electronics, machinery, plastics, metals.
• Technology and software transfers, including ‘sectoral software’ (ERP, CRM, industrial design, and software-as-a-service).
• Expanded the schedules in the 2019 regulations, covering:
  • Critical-industry goods & technology.
  • Energy-related goods & technology.
  • Defence & security goods & technology.
  • G7 dependency goods & technology.
  • “Russia’s vulnerable goods & technology.”

KEY SANCTIONS NOTICES

Designation of Entities under Counter-Terrorism Sanctions (25 September 2025)

On 25 September 2025, two entities — Rampage Productions (Unique ID: CTD0007) and Embers of an Empire (Unique ID: CTD0008) — were designated under the Counterterrorism (Sanctions) (EU Exit) Regulations 2019. Both organisations are now subject to an asset freeze due to their involvement in activities linked to terrorism. The designations specifically relate to the promotion, encouragement, and financing of terrorism through extremist music and associated organisations.

UK, EU, and US Escalate Sanctions on Russian Energy Sector (October 2025)

On 15 October 2025, the United Kingdom imposed sanctions on Russia’s two largest oil companies, Rosneft and Lukoil, following earlier sanctions in January against Gazprom Neft and Surgutneftegas, the country’s third- and fourth-largest producers. The UK also extended restrictions to specialised LNG tankers and the Chinese Beihai LNG terminal, tightening control over Russian energy exports. In addition, the UK announced a ban on imports of refined oil products derived from Russian-origin crude oil, even when processed in third countries such as Thailand, Singapore, Turkey, and China. These measures align with broader international efforts to constrain Russia’s energy revenues.

The European Union followed suit on 23 October 2025 with its 19th package of sanctions, banning the import of Russian liquefied natural gas into the EU starting January 2027. Similarly, the US introduced sanctions targeting Rosneft and Lukoil. Collectively, these coordinated actions by the UK, EU, and US mark a significant escalation in energy-related sanctions, intensifying pressure on Russia’s oil and gas sector while reshaping global energy supply chains.

RECENT CASE LAW

Tonzip Maritime Ltd v 2Rivers PTE Ltd [2025] EWHC 2036 (Comm)

A Voyage charter for carriage of oil cargo from Ust Luga/ Primorsk to the Mediterranean was arranged between the two contracting parties. The shipowner, Tonzip, refused to load cargo shipped by Neftisa, believing it to be linked to Mr Mikhail Gutseriev, who is sanctioned under UK and EU policies. This belief stemmed from screening results from Refinitiv/ World-Check, suggesting a historic association or ownership between Neftisa and Mr Gutseriev. As a result, the charterparty was cancelled. Tonzip terminated the contract as a repudiatory breach.

The Commercial Court ruled against Tonzip due to their reliance on the Refinitiv/ World-Check report. Whilst the reports indicated a historic connection between Neftisa and Mr Gutseriev, there was no evidence of current control at the relevant time. Tonzip had not considered contradictory evidence, including a report which showed that Mr Gutseriev had stepped down, and materials which indicated that control had passed. Tonzip’s decision to terminate the charterparty was based on a decision that was deemed speculative, and not objectively reasonable.

This decision emphasises that compliance with sanctions must stem from careful, evidence-based, objectively reasonable decision-making to avoid wrongfully terminating a contract, and thus increasing exposure to damages.

The case is currently subject to an appeal before the Court of Appeal, and further updates will be provided as proceedings develop. A link to the judgment is here.

REGULATION/TOOLS UPDATE

OFSI Updates

On 13 October 2025, the FCDO, OFSI, and HM Treasury confirmed that from 28 January 2026, the UK Sanctions List will be the single authoritative source of UK sanctions designations. The OFSI Consolidated List and accompanying search tool will no longer be updated. This change arises from a cross-government review and industry feedback and is expected to help streamline the sanctions screening process. Further guidance can be found here.

The consultation window for OFSI’s paper closed on 13 October 2025. Whilst the government response is still outstanding, proposed reforms from the consultation paper include:

• Higher maximum penalties: OFSI proposes raising the cap to the greater of £2 million or 100% of the breach value and is seeking feedback on turnover-based or per-breach models.
• Clearer framework & reduced discounts: A new severity-conduct matrix would clarify penalty outcomes, raise baseline penalty ranges, and cap voluntary disclosure discounts at 30%.
• Settlement scheme: Companies could settle cases within 30 business days for an extra 20% discount, waiving appeal rights in exchange for faster resolution.
• Early Account Scheme (EAS): Allows firms to self-investigate and report within six months for a higher (up to 40%) settlement discount, promoting quicker case closure.
• Simplified process for minor breaches: Standard fines of £5k–£10k and shorter 15-day timelines for low-level information or licensing violations.

FOREIGN INFLUENCE REGISTRATION SCHEME (FIRS)

On 1 July 2025, the Foreign Influence Registration Scheme (FIRS) came into force under the National Security Act 2023. The scheme introduces a two-tier system designed to enhance transparency about foreign influence in UK politics. It requires individuals or organisations acting on behalf of foreign powers or entities to register certain activities, ensuring openness about foreign involvement. The two types of activities that may need to be registered are political influence activities and activities carried out under foreign arrangements.

1. Political influence tier

If a person or entity is instructed by a foreign power to carry out, or arrange for others to carry out, political influence activities in the UK. The guidance on the political influence tier defines ‘political influence activities’ as activities which meet both criteria:

Criteria 1: The activity is one of the following:

• A communication (for example, an email, letter or meeting) to a senior public official or politician.
• A public communication (for example, the publication or production of an article) except where it is reasonably clear that it is made at the direction of a foreign power (for example, if an article is labelled in a way that makes this fact clear, or if the writer mentions this fact in the article itself).
• The provision of money, goods or services to an individual or entity in the UK (for example, providing consultancy services to a UK business). Activities are only in scope of FIRS if they are carried out in the UK.

Criteria 2: The purpose, or one of the purposes, of the activity is to influence one of the following:

• An election or referendum in the UK.
• A decision of a Minister or Government department (including a Minister or Government department of Wales, Scotland or Northern Ireland).
• The proceedings of a UK registered political party (such as their manifesto commitments).
• A Member of the House of Commons, House of Lords, Northern Ireland Assembly, Scottish Parliament or Senedd Cymru (when acting in their capacity as such).

The communication would have to be made in a UK publication, or intended at an audience in the UK, before it is considered a taking place in the UK.

Further guidance can be found here.

If a person or entity is instructed by a specified foreign power or specified foreign power-controlled organisation to carry out, or arrange for others to carry out, ‘relevant activities’ in the UK. The guidance on the enhanced tier defines relevant activities as:

“The default is that “relevant activities” include all activities in the UK. This includes, but is not limited to, commercial activities, research activities and the provision of goods and services (except where this is exempt).“

Under the enhanced tier, the organisations and foreign powers specified are from Russia and Iran.

Lawyers providing legal services are exempt from registering for FIRS. The guidance phrases this exemption as:

“Lawyers, in their provision of legal services to foreign powers (for example, those representing specified foreign powers in a court case)”.

Further guidance can be found here.

CONCLUSION 

There has been a significant tightening of global sanctions regimes, accompanied by increased scrutiny of compliance and transparency obligations. The reinstatement of UN sanctions on Iran, expanded measures targeting Russia’s oil, defence, and crypto sectors, and the introduction of the UK’s Foreign Influence Registration Scheme all highlight an increasingly complex regulatory environment.

MR’s monthly sanctions update will continue to monitor these developments, providing timely insight into new designations, regulatory reforms, and key enforcement trends shaping the global compliance landscape.