News Type: Blogs

KEY DEVELOPMENTS

• Russia-focused multilateral action: EU adoption of its 20th package of sanctions against Russia, adding 120 new listings and expanding restrictions across energy, military-industrial, trade, financial services and crypto-asset sectors, alongside enhanced anti-circumvention measures targeting shadow fleet operations and third-country intermediaries; accompanying US licensing activity facilitating limited operational continuity, including in relation to Lukoil-linked assets and pre-existing oil shipments; UK amendment to an existing Russia designation.

• Expansion of licensing and wind-down measures: Continued reliance by OFAC on general licenses to permit the orderly wind-down of transactions and limited ongoing activity across multiple regimes, including Iran, Nicaragua and Venezuela, as well as authorisations supporting administrative and day-to-day operations for US persons in Russia, reflecting a calibrated approach to maintaining core prohibitions while allowing practical disengagement and compliance with local requirements.

• UK sanctions framework reform and enforcement focus: Publication of OFSI’s Strategy for 2026 to 2029 introducing a revised implementation and enforcement model, coupled with the Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026 establishing a new criminal offence targeting circumvention by diversion and updating licensing grounds, procedural mechanisms and financial thresholds.

• Strengthening of anti-circumvention controls: Introduction of UK Sanctions End-Use Controls extending licensing requirements to goods and technology at risk of onward diversion to sanctioned jurisdictions, supported by detailed government guidance emphasising risk-based due diligence, supply chain visibility and enhanced compliance obligations.

• Guidance and general license developments: Updated UK guidance clarifying the operation of sanctions exceptions and licences across regimes, including the interaction between financial and trade restrictions; issuance of new and revised UK general licences, including a Legal Services General Licence and an insolvency-related licence concerning the Prince Group, reflecting continued refinement of licensing frameworks.

• Geopolitical recalibration of sanctions regimes: Further easing of UK Syria sanctions, including removal of certain trade restrictions and confirmation of broader reforms aimed at supporting economic recovery, alongside targeted US measures permitting limited commercial engagement with the Government of Venezuela and associated entities.

GLOBAL SANCTIONS

AFGHANISTAN

• On 14 and 16 April 2026, the Foreign, Commonwealth & Development Office updated the UK Sanctions List under the Afghanistan (Sanctions) (EU Exit) Regulations 2020, making a series of variations to existing entries. The amendments relate to updates to identifying information, including names, aliases and other biographical details for designated individuals. All affected persons remain subject to asset freezes and travel bans, and the variations do not alter the underlying sanctions measures.

• On 29 April 2026, the Foreign, Commonwealth & Development Office updated the UK Sanctions List under the Afghanistan regime, making 17 variations to existing entries. All individuals remain subject to asset freezes and travel bans, with the updates reflecting changes to identifying information and designation details.

IRAN

• On 24 April 2026, OFAC issued General License V under Executive Order 13902, authorising the wind-down of transactions involving Hengli Petrochemical (Dalian) Refinery Co., Ltd. The licence permits activities ordinarily incident and necessary to terminate existing dealings with the entity and its majority-owned subsidiaries until 24 May 2026, subject to conditions. In particular, any payments to blocked persons must be made into blocked, interest-bearing accounts in the United States. The measure reflects a targeted wind-down authorisation, allowing the orderly cessation of pre-existing business while maintaining broader prohibitions on dealings with sanctioned parties.

NICARAGUA

• On 16 April 2026, OFAC issued General License No. 5 under the Nicaragua Sanctions Regulations, authorising transactions ordinarily incident and necessary to the wind down of activities involving Exportadora de Metales Sociedad Anonima (EMSA) and entities in which it holds a 50 percent or greater interest. The authorisation remains in effect until 12:01 a.m. EDT on 16 May 2026, subject to the condition that any payments to blocked persons are made into blocked accounts.

RUSSIA

• On 8 April 2026, OFAC issued General License 13Q under the Russian Harmful Foreign Activities Sanctions Regulations, authorising certain administrative transactions necessary for the day-to-day operations of U.S. persons in Russia. The licence permits payments such as taxes, fees and import duties, as well as the receipt of permits, licences and similar authorisations, where these would otherwise be restricted under Directive 4. The measure is intended to allow continued basic operational compliance with local legal requirements, while maintaining broader prohibitions, including restrictions on dealings with blocked persons and limitations on access to accounts of key Russian state financial institutions.

• On 14 April 2026, OFAC issued General License 128C under the Russian Harmful Foreign Activities Sanctions Regulations, authorising certain transactions involving Lukoil retail service stations located outside Russia. The licence permits activities necessary for the continued operation, maintenance or wind-down of such stations, including the purchase of goods and services, subject to conditions. The measure reflects a targeted approach to allow limited commercial continuity outside Russia, while preserving core sanctions restrictions, including prohibitions on transfers to Russia and dealings with other blocked persons.

• On 14 April 2026, OFAC also issued General License 130A under the Russian Harmful Foreign Activities Sanctions Regulations, authorising transactions involving specified Lukoil entities operating in Bulgaria. The licence permits otherwise restricted dealings with these entities until 29 October 2026, reflecting a continued effort to manage the impact of sanctions on energy infrastructure and regional markets. The authorisation remains limited in scope and does not extend to other blocked affiliates or broader transactions prohibited under the Russian sanctions regime.

• On 17 April 2026, OFAC issued General License 134B under multiple Russia-related sanctions authorities, authorising transactions necessary for the delivery and offloading of Russian-origin crude oil and petroleum products loaded onto vessels prior to 17 April 2026. The licence provides a time-limited wind-down period, allowing such cargoes to be delivered through 16 May 2026, including associated services required for safe transport and handling. The measure is intended to facilitate the orderly completion of pre-existing shipments, while maintaining restrictions on new transactions and broader sanctions prohibitions.

• On 23 April 2026, the Council of the European Union adopted its 20th package of sanctions against Russia, introducing 120 additional listings alongside expanded economic measures targeting energy revenues, the military-industrial sector, trade and financial services, including crypto-assets. The package also includes strengthened anti-circumvention measures, new restrictions on access to sensitive technologies, and further action targeting the shadow fleet and third-country intermediaries involved in sanctions evasion.

• On 29 April 2026, the Foreign, Commonwealth & Development Office amended an entry on the UK Sanctions List under the Russia regime, updating the designation for one individual. The individual remains subject to asset freeze, travel ban, trust services and director disqualification measures.

SYRIA

• On 22 April 2026, the UK Government updated its guidance on the Syria sanctions regime following amendments to the Syria (Sanctions) (EU Exit) Regulations 2019, including the removal of restrictions relating to gold, precious metals, diamonds and luxury goods. The update builds on earlier reforms introduced in April 2025, which lifted a range of trade, financial, transport and energy-related sanctions to support Syria’s economic recovery, while maintaining targeted measures against former regime figures and associated persons. The guidance also reflects the lifting of asset freezes on certain previously designated state-linked entities, including financial institutions and energy companies, and confirms that the Government of Syria is not currently designated under UK sanctions, underscoring a continued shift towards facilitating investment and reconstruction while preserving accountability measures.

VENEZUELA

• On 14 April 2026, OFAC issued General Licences 56 and 57 under the Venezuela Sanctions Regulations, authorising certain commercial and financial activities involving the Government of Venezuela and specified state-linked entities. The measures permit U.S. persons to engage in negotiations of contingent commercial arrangements with the Government of Venezuela, as well as to provide a broad range of financial services involving designated Venezuelan banks and certain government-affiliated individuals, subject to conditions. The licences form part of a broader easing of restrictions aimed at facilitating limited commercial engagement and improving access to financial channels, while maintaining core sanctions prohibitions, including restrictions on entering into or performing contracts without further authorisation and the continued application of asset freezes and other targeted measures.

GLOBAL REGULATIONS/ TOOLS UPDATE

• On 15 April 2026, OFSI published its Strategy for 2026–2029, setting out an updated framework for the implementation and enforcement of UK financial sanctions. The strategy introduces a new operating model built around four pillars, Promote, Enable, Respond and Change, aimed at improving compliance clarity, streamlining licensing processes, strengthening enforcement activity and embedding long-term behavioural change across regulated sectors. It also emphasises a more data-driven and intelligence-led approach, enhanced engagement with industry, and closer coordination with domestic and international partners, reflecting a broader shift towards proactive compliance support alongside more targeted and effective enforcement.

• On 20 April 2026, the UK Government made the Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026 (SI 2026/443) under the Sanctions and Anti-Money Laundering Act 2018 (SAMLA 2018) which come into force on 13 May 2026. The regulations introduce a new criminal offence aimed at addressing the risk of sanctions circumvention through diversion. The offence applies where a UK person proceeds to export goods or transfer technology after being notified by the Secretary of State that there is a risk those items could be diverted to a sanctioned destination or end user, without first obtaining a licence. The Regulations implement these end-use controls across a number of trade sanctions regimes, including those relating to Russia, Belarus, Iran, Syria and Myanmar, with licence applications to be assessed on a case-by-case basis. The amendments also revise the “prior obligations” licensing ground so that obligations are no longer limited to being discharged using a designated person’s frozen funds or by that person alone, and remove that ground entirely from the Afghanistan regime. Additional changes include updating financial thresholds for certain regulated sectors, allowing licensing decisions to be communicated electronically, clarifying the scope of the debt payment exception, and removing outdated statutory references, reflecting a broader effort to enhance the effectiveness and operability of the UK sanctions framework.

• On 22 April 2026, the UK Government introduced new Sanctions End-Use Controls and issued guidance for businesses, establishing a licensing requirement where exporters are aware, or have been notified, that goods or technology exported to non-sanctioned countries may ultimately be diverted to sanctioned destinations or end users. The measures are intended to address circumvention risks and apply to items not otherwise subject to existing military or dual-use export controls, thereby expanding the scope of regulated activity. The guidance outlines compliance expectations, including responding to government notifications, undertaking risk-based due diligence on end use and end users, and maintaining appropriate records, reflecting an increased emphasis on supply chain scrutiny and enforcement.

• On 23 April 2026, the UK Government updated its guidance on how to use exceptions and licences to comply with sanctions, providing consolidated direction across financial, trade and transport regimes. The guidance clarifies the distinction between “exceptions”, which operate as automatic exemptions where specific conditions are met, and “licences”, which constitute formal authorisation to undertake otherwise prohibited activities. It also outlines the role of different competent authorities in issuing licences across regimes and emphasises the need for businesses to assess applicability carefully, including compliance with any notification and record-keeping requirements attached to exceptions. The update highlights the potential for overlapping financial and trade restrictions, reinforcing the importance of ensuring that all necessary permissions are obtained before proceeding with sanctioned activities. The guidance can be found here.

General Licences

General Licence INT/2026/9512597 (Legal Services), issued 24 April 2026

OFSI issued General Licence INT/2026/9512597, introducing a new framework permitting UK legal firms and counsel to receive payment from designated persons for legal services, subject to specified conditions. The licence replaces the previous Legal Services General Licence expiring on 28 April 2026, takes effect from 29 April 2026, and remains in force until 28 October 2026, with associated reporting and record-keeping requirements applying.

General Licence INT/2026/9491628 (Prince Group Insolvency), issued 14 April 2026

This licence permits insolvency-related payments and activities in connection with the sanctioned Prince Group and its subsidiaries, including the making, receiving and processing of payments necessary for insolvency proceedings, without breaching UK financial sanctions. It applies to insolvency practitioners, relevant institutions and other persons involved in such proceedings, provided that any funds or economic resources remain frozen and are not made available for the benefit of designated persons except as permitted. The licence imposes notification requirements to HM Treasury within 14 days of relevant activity and requires records to be maintained, reflecting a targeted approach to facilitate orderly insolvency processes while preserving asset freeze restrictions.

CONCLUSION

April’s developments highlight the increasing focus by US, UK and EU authorities on targeted licensing, regulatory reform and enhanced anti-circumvention tools as key mechanisms for shaping the global sanctions landscape. The expanded use of general licences to facilitate wind-downs and limited commercial activity, alongside significant EU measures relating to Russia, reflects a continued effort to balance geopolitical objectives with practical compliance considerations. At the same time, the UK’s introduction of new end-use controls and updated enforcement strategy signals a more proactive and operationally focused approach to sanctions implementation, with a growing emphasis on supply chain scrutiny and risk-based compliance. These developments contribute to an increasingly complex and enforcement-driven environment for businesses and financial institutions operating across jurisdictions. MR’s monthly sanctions update will continue to monitor these developments, providing timely insight into international sanctions measures, regulatory reforms and key enforcement trends shaping the global sanctions landscape.

This blog post is not offered, and should not be relied on, as legal advice. You should consult an attorney for advice in specific situations.

The imposition of sanctions following Russia’s war on Ukraine resulted in a flurry of commercial cases. While these commercial decisions have been useful in guiding parties’ approach to sanctions implementation, the clearest guidance on OFSI’s approach comes from enforcement cases, which have been rarer.

In one such recent case, OFSI has imposed a £390,000 penalty on Apple Distribution International Limited (ADI), an Irish-incorporated subsidiary of Apple Inc., for making funds available to an entity owned or controlled by a designated person in breach of regulation 12 of the Russia (Sanctions) (EU Exit) Regulations 2019.

This is the first case under OFSI’s settlement regime and is a useful illustration of how UK sanctions can apply to non-UK entities, as well as OFSI’s approach in practice.

Background

ADI operates Apple’s App Store in Europe and the Middle East. It collects revenues from the App Store and instructs payments to app developers through a UK bank account; one of those developers was a Russian media streaming business, Okko LLC (Okko).

Okko had previously been owned by Sberbank, Russia’s largest bank, which the UK designated in April 2022. In May 2022, Sberbank sold Okko to a newly created entity, JSC New Opportunities, which was itself designated on 29 June 2022. From that point, Okko was again subject to asset-freeze restrictions as a wholly owned subsidiary of a designated person.

ADI made two payments to Okko from the UK account: Payment A was instructed on 6 June 2022 and released on 30 June 2022; Payment B was instructed on 30 June 2022 and released on 28 July 2022, by which point JSC New Opportunities had been designated for approximately a month. The total amount transferred was £635,618.75.

Jurisdiction and strict liability

ADI is not subject to UK sanctions law as it is incorporated in Ireland. However, its conduct was treated as occurring in the UK on the basis that ADI had instructed a UK bank to make the payments. As UK sanctions regimes apply to any conduct within the UK, the instruction of a UK bank triggers the application of UK sanctions.

The strict liability regime was introduced in 2022, by means of amendments to the Policing and Crime Act 2017, after which an entity is liable for breaches of sanctions regimes even if it had no knowledge of the breach or reasonable cause to suspect one. Given the payments to Okko were made following its designation, OFSI found that ADI was liable despite the fact that it had neither knowledge of the breach nor reasonable cause to suspect one. Under the Enforcement Guidance, OFSI found the breach to be “serious” rather than “most serious”. Further, in its assessment of the case, OFSI considered several factors, and assessed their relevance to aggravation or mitigation, which then informs how seriously OFSI views a case.

Aggravating factors

In this case, OFSI found that there were several aggravating factors.

First, ADI had a compliance framework in place which relied on self-certification and third-party due diligence providers; OFSI’s view was that it was inadequate for the sanctions climate at the time of breach because of Russian corporate ownership changing rapidly following the invasion of Ukraine. Contemporaneous open-source reporting described Sberbank’s sale of its assets and highlighted that JSC New Opportunities had been created specifically to acquire them. These factors were not identified by the third-party due diligence mechanisms in place.

OFSI also concluded that ADI failed to affirmatively request ownership information from Russian developers, which would have materially increased the chance of identifying the risk, and was considered an aggravating factor. OFSI also reiterated that ADI, as the entity making the payments, remained responsible for the adequacy of its own controls and had ultimate responsibility for ensuring sanctions compliance.

The fact that ADI made two previous payments to Okko in April 2022 (while it was designated), prior to the strict liability regime coming into force, was also considered an aggravating factor. Lastly, Russia sanctions were also treated as a strategic UK priority, which added to the weight given to the seriousness of the breach.

Mitigation

There were also several mitigating factors in this case. OFSI accepted that ADI had neither intent, knowledge, nor reasonable cause to suspect the breach. Payment A was completed on the day of designation, in a window so narrow that OFSI acknowledged automated systems would not necessarily be expected to catch it.

ADI also made a voluntary disclosure in October 2022, cooperated fully with the investigation, and subsequently enhanced its framework, including introducing a process to require Russian developers to provide direct and indirect ownership information at onboarding and periodically thereafter. Those steps were considered as mitigating factors when OFSI calculated the penalty.

Penalty and settlement

The baseline penalty was £600,000 against a statutory maximum of £1,000,000. A reduction of 35% was applied to reflect voluntary disclosure and ADI’s agreement to settle under the transitional arrangements, producing a final penalty of £390,000. The position has since changed. Under OFSI’s updated February 2026 enforcement guidance, voluntary disclosure is capped at 30% and a separate 20% discount applies for settlement.

Settlement itself is a new mechanism, and this is the first time OFSI has used it. Settlement requires the subject to pay the penalty as imposed and to waive rights of review and appeal to the Upper Tribunal. In return, the subject may contribute to the published case summary and will receive the settlement discount if agreement is reached within 30 business days. Firms facing investigation should consider whether to engage early to obtain the 20% discount.

Conclusion

Firms are under continued obligation to comply with sanctions. Where any part of the conduct engages the UK’s jurisdiction, including the payment mechanics, UK sanctions come into operation. Parties should note the following:

1. Ongoing awareness of, and compliance with, UK sanctions regimes remains necessary. The strict liability regime means lack of knowledge of the breach or intent to cause it is not an excuse.
2. Any act taking place within the UK requires compliance with UK sanctions, including the use of UK banks. Any business routing payments through UK financial infrastructure should treat UK sanctions obligations as directly applicable to it.
3. Firms have a continuing obligation to assess ownership and control, especially where ownership structures are complex, opaque, or subject to change.
4. Third-party providers are helpful, but they do not displace responsibility away from the party using them. The firm using the provider is still responsible for a sanctions breach, if the data is incomplete or delayed. Merely adopting third-party vendors will not reduce a firm’s liability.
5. Where a potential breach is identified, voluntary disclosure remains one of the most effective tools available to obtain a reduced penalty and OFSI expects disclosure promptly after discovery. Firms should also be aware of the settlement framework following the demonstration of its practical application. Given that the discount narrows if settlement is not reached within 30 business days, there is a real incentive to engage early.

This blog post is not offered, and should not be relied on, as legal advice. You should consult an attorney for advice in specific situations.

KEY DEVELOPMENTS

• Major US, UK and EU designations: EU cyber sanctions against Integrity Technology Group, Anxun Information Technology and associated individuals linked to hacking activity affecting EU member states and partners; EU human rights sanctions against 16 individuals and three entities in Iran in connection with the authorities’ handling of protests earlier in 2026; EU cyber sanctions against Iranian entity Emennet Pasargad; EU Russia-regime listings targeting individuals involved in foreign information manipulation and interference and nine individuals linked to atrocities committed during the Bucha massacre.

• Sanctions litigation and enforcement developments: Central Bank of Russia challenge before the EU General Court to measures providing for the indefinite freezing of its assets held in the EU; German criminal convictions for the export of luxury vehicles to Russia in breach of EU restrictions, including custodial sentences and confiscation of proceeds; OFSI monetary penalty of £390,000 imposed on Apple Distribution International for breaches of UK Russia financial sanctions.

• General licences: OFAC General License No. 14 under the Belarus programme authorising certain transactions involving Belinvestbank Joint Stock Company and related entities; OFAC General License No. 1 under the DRC programme authorising wind-down transactions involving the Rwanda Defence Force; OFAC General License U authorising certain transactions relating to Iranian-origin crude oil and petroleum products loaded by 20 March 2026; OFAC General License 134 authorising certain transactions relating to Russian-origin crude oil and petroleum products already loaded onto vessels as of 12 March 2026; OFSI General Licence INT/2026/9247168 authorising certain activities involving PJSC Transneft in connection with Kazakh-origin crude oil.

• Russia-related developments: EU listings targeting foreign information manipulation and individuals linked to Bucha atrocities; OFAC extension of the deadline for negotiations relating to the potential sale of Lukoil’s foreign assets to 1 May 2026; updated UK guidance on countering Russian sanctions evasion and circumvention; OFSI enforcement action against Apple Distribution International for payments to a Russian entity owned by a designated person.

• Regulatory and guidance updates: UK publication of its cross-government strategic approach to sanctions enforcement; updated UK statutory guidance under the Central African Republic regime; UK guidance on Belarus trade sanctions licensing, including a structured tool for assessing licence availability; updated UK Starter Guide to Sanctions; OFSI update on evidential requirements and “reasonableness” in licence applications; OFSI open call for evidence on the ownership and control test closing on 13 April 2026; UK Sanctions List updates under the Afghanistan regime making variations to identifying information on existing entries.

• Trade controls and export licensing: ECJU update to the Open General Export Licence for military goods: Collaborative Project Typhoon, including expansion of permitted destinations.

GLOBAL SANCTIONS

AFGHANISTAN

• On 11 March 2026, the Foreign, Commonwealth & Development Office updated the UK Sanctions List under the Afghanistan (Sanctions) (EU Exit) Regulations 2020, making 22 variations to existing entries. The changes relate to updates to identifying information, including dates of birth, passport details, aliases and other biographical data for listed individuals. All affected persons remain subject to asset freezes and travel bans, and the variations do not alter the underlying sanctions measures.

BELARUS

• On 5 March 2026, the UK Government published guidance setting out considerations for granting trade sanctions licences under the Republic of Belarus (Sanctions) (EU Exit) Regulations 2019. The guidance provides a structured “look-up” tool to assist businesses in determining whether a licence may be available across a range of restricted sectors, including military goods, dual-use items, industrial goods, energy-related products and luxury goods. It outlines the types of circumstances in which licences may be granted, such as for humanitarian purposes, protective use or certain civil applications, and emphasises that a licence must be obtained before engaging in any activity otherwise prohibited by the regime.

• On 26 March 2026, OFAC issued General License No. 14 under the Belarus Sanctions Regulations, authorising transactions involving Belinvestbank Joint Stock Company, Belinvest-Engineering, Belbizneslizing, and entities in which they hold a 50 percent or greater interest. The licence permits transactions otherwise prohibited under the regime but does not authorise the unblocking of property or transactions involving other blocked persons not covered by the licence.

CENTRAL AFRICAN REPUBLIC

• On 25 March 2026, the UK Government updated its statutory guidance under the Central African Republic (Sanctions) (EU Exit) Regulations 2020 to reflect changes introduced by the 2025 Amendment Regulations and recent UN Security Council measures. The updated guidance provides further clarity on the operation of financial sanctions, including asset freeze obligations and restrictions on making funds or economic resources available, as well as the scope of remaining trade and export prohibitions following the lifting of the arms embargo. It also expands on the application of director disqualification measures, preventing designated persons from participating in the management of UK companies, and clarifies available exceptions, including the UN humanitarian exemption. The updates are intended to improve usability and support consistent compliance without materially altering the underlying framework.

CHINA

• On 16 March 2026, the Council of the European Union imposed restrictive measures under its cyber sanctions regime on Integrity Technology Group and Anxun Information Technology, as well as the two co-founders of Anxun. The designations relate to the provision of hacking tools and services used to compromise devices and target critical infrastructure in EU member states and partner countries. Those listed are subject to asset freezes, with EU persons prohibited from making funds or economic resources available to them, and the individuals also subject to travel bans.

DEMOCRATIC REPUBLIC OF CONGO

• On 2 March 2026, OFAC issued General License No. 1 under the Democratic Republic of the Congo Sanctions Regulations, authorising transactions ordinarily incident and necessary to the wind down of activities involving the Rwanda Defence Force (RDF) and entities in which it holds a 50 percent or greater interest. The authorisation remains in effect until 12:01 a.m. EDT on 1 April 2026, subject to the condition that any payments to blocked persons are made into blocked accounts.

GERMANY

• On 2 March 2026, a German court convicted two individuals for exporting 111 luxury vehicles to Russia in breach of the EU’s luxury goods restrictions under Article 3h of Regulation (EU) 833/2014. The vehicles, including armoured cars, were supplied to Russian customers via a network of intermediary companies. One defendant received a six-year custodial sentence, while the other was given a two-year suspended sentence. The court also ordered the confiscation of approximately €20 million in proceeds of crime. Authorities indicated that the scheme involved plans to export a further 400 vehicles valued at around €40 million.

IRAN

• On 16 March 2026, the Council of the European Union introduced further sanctions under its Iran human rights regime, adding 16 individuals and three entities in response to the authorities’ handling of protests earlier in 2026. Those designated include senior government, security and judicial figures, as well as organisations linked to the coordination of enforcement measures and surveillance activities. The listings impose asset freezes and travel bans and prohibit EU persons from making funds or economic resources available. The additions bring the total number of listings under the regime to 263 individuals and 53 entities.

• On 16 March 2026, the Council of the European Union imposed sanctions under its cyber regime on Emennet Pasargad, an Iranian entity linked to cyber activities affecting EU member states. The designation relates to unauthorised access to data, including a French subscriber database, and the compromise of advertising billboards and a Swedish SMS service.

• On 20 March 2026, OFAC issued General License U, authorising transactions ordinarily incident and necessary to the sale, delivery or offloading of Iranian-origin crude oil and petroleum products loaded onto vessels on or before 12:01 a.m. EDT, 20 March 2026. The licence applies to such cargoes, including those carried on blocked vessels, and remains in force until 12:01 a.m. EDT, 19 April 2026. It also confirms that authorised transactions may include importation into the United States where such activity is incidental to the permitted sale or delivery. The licence does not authorise transactions involving persons connected with North Korea, Cuba or certain regions of Ukraine, or entities owned or controlled by such persons.

RUSSIA

• On 3 March 2026, the Central Bank of Russia brought proceedings before the EU General Court challenging Council Regulation (EU) 2025/2600, which provides for the indefinite freezing of its assets held in the EU. The claim, filed under Article 263 TFEU, seeks annulment of the measure and raises arguments relating to property rights, access to justice and sovereign immunity, as well as alleged procedural deficiencies in its adoption, including the use of a majority vote rather than unanimity. The case forms part of wider efforts to contest EU measures affecting Russian sovereign assets, estimated at around $300 billion held in Europe.

• On 12 March 2026, the U.S. Treasury’s Office of Foreign Assets Control issued General License 134, authorising transactions ordinarily incident and necessary to the delivery, sale and offloading of Russian-origin crude oil and petroleum products already loaded onto vessels as of that date. The licence provides a time-limited exemption, allowing such cargoes to be completed notwithstanding existing sanctions, and is set to expire on 11 April 2026.

• On 16 March 2026, the Council of the European Union adopted additional sanctions under its framework targeting Russia’s destabilising activities, listing four individuals involved in foreign information manipulation and interference directed at the EU and its partners. Those designated include media figures and propagandists linked to the dissemination of disinformation relating to Russia’s war against Ukraine. Following these additions, the regime applies to 69 individuals and 17 entities.

• On 16 March 2026, the Council of the European Union imposed additional restrictive measures under its Russia sanctions regime, listing nine individuals for their roles in atrocities committed during the Bucha massacre in 2022. The individuals, including senior military personnel, were identified as having played a significant role in actions undermining Ukraine’s territorial integrity and sovereignty, with the EU stating that the conduct in question amounts to war crimes and crimes against humanity.

• On 30 March 2026, OFAC extended, for a fourth time, the deadline for potential buyers to negotiate the purchase of Lukoil’s foreign assets, moving it to 1 May 2026. The extension provides additional time for discussions relating to assets reportedly valued at around $22 billion, with any eventual transaction remaining subject to OFAC approval.

TURKEY

• On 9 March 2026, the U.S. Department of Justice and Türkiye Halk Bankası A.Ş. (Halkbank), a state-owned Turkish bank, agreed a proposed Deferred Prosecution Agreement (DPA) in a long-running U.S. criminal case in which U.S. prosecutors allege that Halkbank participated in a scheme to evade U.S. sanctions on Iran involving approximately $20 billion in transactions. The agreement, filed in the U.S. District Court for the Southern District of New York, would suspend the criminal proceedings subject to court approval. Under the proposed terms, Halkbank would not admit to wrongdoing or pay financial penalties but would be required to implement compliance enhancements, including the appointment of an independent monitor, and refrain from transactions involving Iran during the term of the agreement.

GLOBAL REGULATIONS/TOOLS UPDATE – UK

• UK Government strategic approach to sanctions enforcement: On 10 March 2026, the UK Government published its cross-government strategic approach to sanctions enforcement, setting out how civil and criminal breaches of UK sanctions are investigated and enforced across departments and agencies. The document outlines key enforcement principles, the respective roles of enforcement bodies, and the range of tools available, including civil penalties and criminal action, together with the factors taken into account when determining outcomes. It also emphasises the importance of strong compliance, noting that enforcement is intended both to deter non-compliance and to address deliberate attempts to evade sanctions.

• Open General Export Licence update: On 11 March 2026, the Export Control Joint Unit (ECJU) updated the Open General Export Licence (OGEL) for military goods: Collaborative Project Typhoon, revoking the previous 30 September 2022 licence. The updated licence expands the list of permitted destinations to include Turkey (for maintenance purposes), while continuing to authorise exports of specified military goods, software and technology in support of the Typhoon programme to approved partner nations and permitted end users. The licence remains subject to conditions including prior ECJU approval of eligible contracts, compliance with security requirements, and record-keeping and reporting obligations, with exporters also required to include the relevant licence reference in customs declarations.

• Guidance on countering Russian sanctions evasion and circumvention: On 12 March 2026, the UK Government updated its guidance on countering Russian sanctions evasion and circumvention, aimed at supporting exporters in identifying and mitigating diversion risks. The guidance can be found here. The guidance outlines common evasion tactics, including the use of third-country intermediaries, indirect shipping routes and falsified end-use information, and highlights categories of high-risk goods, particularly military, dual-use and industrial items. It also sets out red flag indicators and recommended enhanced due diligence measures, emphasising that businesses are responsible for assessing their exposure and implementing appropriate compliance controls to avoid facilitating sanctions breaches.

• OFSI updated blog on “reasonableness” in licence applications: On 13 March 2026, OFSI published an updated blog on its approach to assessing “reasonableness” in sanctions licence applications, providing greater clarity on evidential requirements across key licensing grounds. The update introduces a requirement for an independent Costs Draftsperson’s Report in certain high-value legal fee cases, including where total legal fees exceed £2 million (including VAT) within a six-month period, or £1 million where Counsel is instructed directly. These thresholds apply cumulatively per designated person across related applications. OFSI also emphasised that applicants must demonstrate that requested payments are reasonable, supported by appropriate evidence.

• Updated Starter Guide to UK Sanctions: On 25 March 2026, the UK Government updated its Starter Guide to UK Sanctions, an introductory resource designed to help businesses and organisations understand the structure and operation of the UK sanctions regime. The guidance can be found here. The guidance outlines who must comply, the different types of sanctions, including financial, trade, immigration and transport measures, and key concepts such as designated persons, ownership and control, and the UK Sanctions List. It also highlights core compliance expectations, including sanctions screening, due diligence and the use of licensing and exceptions.

• OFSI monetary penalty against Apple Distribution International: On 19 March 2026, OFSI imposed a £390,000 monetary penalty on Apple Distribution International (ADI), with the decision published on 30 March 2026, for breaches of UK financial sanctions relating to Russia. The case concerned two payments totalling £634,570.08, made on 6 June and 8 July 2022, to a Russian entity owned by a designated person. OFSI determined, on the balance of probabilities, that the payments constituted breaches of the asset freeze, notwithstanding that ADI voluntarily disclosed the transactions. The penalty was imposed following settlement discussions and reflects OFSI’s assessment of the seriousness of the breach and mitigating factors.

• OFSI open call for evidence: OFSI’s open call for evidence on the operation of the ownership and control test in UK financial sanctions regulations, including how it is applied in practice and the challenges faced by firms, closes on Monday 13 April 2026. The survey can be accessed here.

General Licences

• On 19 March 2026, OFSI issued General Licence INT/2026/9247168 permitting certain activities involving PJSC Transneft and its subsidiaries in connection with the transportation and handling of Kazakh-origin crude oil. The licence authorises transactions, including payments, relating to the supply, purchase and movement of Kazakh oil where the oil is not owned by a person connected with Russia and is only transiting through or departing from Russia. The licence also allows relevant UK financial institutions to process associated payments. It remains in force until 18 March 2028 and is subject to standard record-keeping requirements.

CONCLUSION

March 2026 reflects an increasingly active sanctions environment, with new EU cyber and Russia-related listings, ongoing litigation such as the Central Bank of Russia challenge, and criminal enforcement in Germany signalling continued regulatory focus. In the UK, recent guidance on enforcement, evasion and licensing, alongside OFSI’s penalty against Apple Distribution International, reinforces the practical impact of the strict liability regime, where breaches may arise without knowledge or intent. At the same time, the use of general licences across US and UK regimes highlights the need for careful navigation of permitted activity within complex restrictions.

Overall, firms should ensure their sanctions compliance frameworks remain proactive, risk-based and responsive to ongoing developments. MR’s monthly sanctions update will continue to monitor these developments, providing timely insight into international sanctions measures, regulatory reforms and key enforcement trends shaping the global sanctions landscape.

This blog post is not offered, and should not be relied on, as legal advice. You should consult an attorney for advice in specific situations.

KEY DEVELOPMENTS

• Major UK and EU designations and Russia escalation: UK announcement of its largest Russia sanctions package to date on 24 February 2026, introducing nearly 300 new designations targeting energy revenues, shadow fleet networks, LNG and civil nuclear sectors, military supply chains and certain financial institutions; EU restrictive measures against additional Russian individuals linked to human rights abuses and repression; continued UK Iran human rights designations; UN Security Council sanctions targeting senior Rapid Support Forces commanders in Sudan.

• Sanctions enforcement and penalty developments: OFSI publication of revised Financial Sanctions Enforcement and Monetary Penalties Guidance introducing a four-level seriousness framework, refined penalty calculation methodology and enhanced discount mechanisms; proposed increase to the UK Statutory Maximum Penalty from the greater of £1 million or 50 percent of breach value to the greater of £2 million or 100 percent of breach value, subject to legislative approval; OFSI case study highlighting compliance failings in the Bank of Scotland Russia sanctions breach. 

• Ownership and control scrutiny: OFSI launch of an open call for evidence on 16 February 2026 regarding the practical operation of the ownership and control test under UK financial sanctions, signalling potential future clarification or reform. 

• Russia-related asset divestment and licensing activity: OFAC extension of the deadline for authorised negotiations relating to the sale of Lukoil’s foreign assets; issuance of UK wind-down General Licences in respect of PJSC Transneft and Maritime Mutual; amendment and extension of the Lukoil Bulgaria continuation licence. 

• US enforcement and policy developments: US authorities strengthened sanctions enforcement infrastructure and policy tools, including the launch of OFAC’s Voluntary Self-Disclosure Portal and FinCEN’s sanctions whistleblower portal, alongside the first designations under the Protecting American Intellectual Property Act (PAIPA), signalling continued expansion of US sanctions authorities and reporting mechanisms.

GLOBAL SANCTIONS 

EU 

• On 26 February 2026, the Council of the European Union strengthened the scope of the EU’s counter-terrorism sanctions regime under Council Common Position 2001/931/CFSP and renewed all existing listings on the EU terrorist list. The framework provides for the freezing of funds and economic resources of listed persons, groups and entities, as well as a prohibition on making funds or economic resources available to them. In confirming the continued application of the regime and broadening its scope, the Council stated that the measures are intended to ensure the EU’s counter-terrorism sanctions remain effective and responsive to evolving security threats.

IRAN

• On 2 February 2026, the Foreign, Commonwealth & Development Office (FCDO) added one entity and ten individuals to the UK Sanctions List under the Iran (Sanctions) Regulations 2023 in response to serious human rights violations and abuses in Iran, including the violent suppression of protestors. The designated organisation is the Law Enforcement Forces of the Islamic Republic of Iran, which is subject to an asset freeze and director disqualification sanction. The ten individuals added include senior Iranian officials such as Eskandar Momeni, Mohammad Reza Hashemifar, Ahmed Amini, Mohammad Ghanbari, Ahmad Darvish Goftar and Mehdi Rasakhi, among others, who are sanctioned for their roles in violent crackdowns, arbitrary detention and serious human rights abuses.

• On 25 February 2026, OFAC designated multiple entities, individuals and vessels involved in facilitating Iranian petroleum sales and related financial flows, including networks used to disguise the origin of Iranian oil shipments. Those designated were added to the Specially Designated Nationals and Blocked Persons (SDN) List, triggering asset freezes and prohibiting U.S. persons from engaging in transactions with them.

MYANMAR

• On 10 February 2026, the FCDO issued a Sanctions Notice under the Myanmar (Sanctions) Regulations 2021 correcting an entry on the UK Sanctions List. The amendment updated the designation details for Sky One Construction Company Ltd, which remains subject to UK sanctions including an asset freeze and director disqualification sanction. The UK statement of reasons notes that the company contributed funds to the Myanmar Security Forces in 2017. The notice clarifies the entry but does not remove the entity from the sanctions list. All relevant prohibitions and reporting obligations continue to apply.

NICARAGUA 

• On 26 February 2026, OFAC sanctioned five Nicaraguan officials for their alleged roles in supporting repression by the Ortega–Murillo regime. Those designated include senior officials from Nicaragua’s Financial Analysis Unit, Ministry of Labor, telecommunications regulator, and military intelligence directorate. OFAC cited the ongoing repression of political opponents, restrictions on media freedom, and constitutional changes consolidating executive power.

RUSSIA 

• On 10 February 2026, the FCDO published a Sanctions Notice under the Russia (Sanctions) (EU Exit) Regulations 2019 that updates the UK Sanctions List entry for Digital Security Services LLC. The notice refines the details associated with the company’s listing, including corrections to its name and related identifiers, to improve accuracy in the sanctions register. The variation does not remove the company from the sanctions list and does not change the substantive sanctions measures applied to it. Digital Security Services LLC remains subject to the UK’s financial sanctions regime.

• On 13 February 2026, the FCDO issued a Sanctions Notice updating the UK Sanctions List under the Russia (Sanctions) (EU Exit) Regulations 2019 by varying the listing for Saodat Narzieva. The variation removed a reference to Narzieva “obtaining a financial or other material benefit from Alisher Usmanov” while keeping her subject to UK sanctions measures, including an asset freeze, travel ban, trust services sanctions and director disqualification sanction. Narzieva was originally designated on 13 April 2022 as an “involved person” under the Russia regime based on her familial and associational links to Usmanov. The update does not alter the underlying sanctions obligations, which continue to apply.

• On 23 February 2026, the Council of the European Union adopted restrictive measures targeting eight additional individuals responsible for serious human rights violations, the repression of civil society and democratic opposition in Russia, and the undermining of the rule of law. The newly listed individuals include members of the Russian judiciary involved in politically motivated trials and senior figures in the penal system connected to inhumane detention conditions for political prisoners, including activists sentenced on politically motivated charges. Those designated are subject to asset freezes and travel bans.

• On 24 February 2026, marking four years since Russia’s full-scale invasion of Ukraine, the UK Government announced what it described as its largest sanctions package to date against Russia, introducing nearly 300 new designations and bringing the total number of UK targets under the Russia regime to over 3,000. The measures focus heavily on Russia’s energy revenues, including action against PJSC Transneft, networks involved in trading Russian oil, dozens of oil tankers linked to circumvention activity, and entities connected to the LNG and civil nuclear sectors, as well as additional suppliers supporting Russia’s military capabilities and certain financial institutions facilitating cross border payments. The Government stated that the package is intended to further restrict the Kremlin’s ability to generate revenue and sustain its war effort, while reinforcing the UK’s continued support for Ukraine.

• On 26 February 2026, reporting indicated that OFAC extended the deadline under its existing OFAC authorisation permitting negotiations and preparatory steps for the sale of Lukoil’s foreign assets, moving the cut-off from 28 February 2026 to 1 April 2026. The extension continues the effect of the prior authorisation and provides additional time for potential buyers to progress divestment discussions while underlying sanctions remain in force.

• On 26 February 2026, during a parliamentary committee session, a UK government minister indicated that the UK could consider joining the EU in pursuing a ban on the provision of maritime services relating to Russian oil shipments, even if the United States does not adopt equivalent measures. The comments signal potential further tightening of restrictions targeting Russian oil exports and associated shipping and insurance services.

SUDAN 

• On 25 February 2026, the UN Security Council imposed sanctions on four senior commanders of Sudan’s paramilitary Rapid Support Forces (RSF) for their roles in the capture of el-Fasher on 26 October 2025, which a UN fact-finding mission described as involving mass atrocities. The individuals designated are RSF deputy commander Abdul Rahim Hamdan Dagalo, Brigadier General Al-Fateh Abdullah Idris (Abu Lulu), Gedo Hamdan Ahmed, and Tijani Ibrahim. The sanctions, which may include asset freezes and travel bans under UN authorities, follow previous designations by the United States and the United Kingdom relating to the same conduct. According to the UN refugee agency, more than 70,000 civilians have fled el-Fasher since it was captured.

SYRIA 

• On 25 February 2026, OFAC announced a $3,777,000 settlement with a US individual for 20 apparent violations of the former Syria Sanctions Regulations. Between 2018 and 2021, the individual provided managerial services to Syrian real estate companies while serving as an executive and board member. OFAC characterised the conduct as egregious and not voluntarily disclosed. Although US sanctions on Syria were lifted in 2025, OFAC emphasised that the removal of sanctions does not extinguish liability for past breaches, underscoring its continued enforcement posture.

GLOBAL REGULATIONS/TOOLS UPDATE – UK 

FCDO updated UK Sanctions List search tool user guide 

On 12 February 2026, FCDO published an updated user guide for the UK Sanctions List search tool. The guide explains how to use the search function and accompanying filters to identify individuals, entities and vessels subject to UK sanctions. The user guide can be found here. 

FCA publishes guidance on reporting suspected sanctions evasions 

On 12 February 2026, the UK Financial Conduct Authority published new guidance on reporting suspected sanctions evasion, clarifying how regulated firms and professionals should notify the FCA of suspected or actual sanctions evasion and weaknesses in sanctions controls. The guidance outlines reporting routes, including the FCA’s wrongdoing or misconduct reporting form and its whistleblowing channels, and emphasises that firms should report suspected breaches, control deficiencies or methods used to circumvent sanctions, particularly where these involve firms or individuals on the FCA’s registers or UK-listed securities. The guidance can be found here.

Updated OFSI guidance on financial sanctions enforcement and monetary penalties 

On 9 February 2026, OFSI updated its Financial Sanctions Enforcement and Monetary Penalties Guidance following a 12-week public consultation in 2025 on enhancing OFSI’s civil enforcement framework. The revised guidance introduces a clearer four-level seriousness categorisation for breaches and refines the case factors OFSI considers, including greater emphasis on management of sanctions risk and the strategic priority of the relevant regime. It sets out in more detail how OFSI determines the statutory maximum penalty, which is the greater of £1 million or 50 percent of the estimated value of the breach where that value can be assessed, and how it then establishes a reasonable and proportionate baseline penalty, with indicative guidance that the most serious Level 4 cases should generally attract a baseline at or above 75 percent of the statutory maximum. The guidance also formalises three potential discounts to that baseline penalty: up to 30 percent for voluntary, prompt and complete self-reporting combined with proactive cooperation, up to 20 percent under a new Early Account Scheme for early factual admissions, and a 20 percent settlement discount, with cumulative application where more than one applies. Additional updates include a new policy on assessing claims of financial hardship and expanded guidance on fixed monetary penalties for certain information, reporting and licensing breaches. The Government states that the changes are intended to increase transparency, incentivise early engagement, and ensure enforcement outcomes remain effective, proportionate, and consistent. The full guidance can be found here. 

Proposed increase to the UK’s Statutory Maximum Penalty 

In a 29 January 2026 blog post, OFSI Director Giles Thomson confirmed that the Government intends to increase the statutory maximum monetary penalty for financial sanctions breaches from the current threshold of the greater of £1 million or 50 percent of the estimated value of the breach to the greater of £2 million or 100 percent of the estimated value. Because the statutory maximum is set out in primary legislation under the Policing and Crime Act 2017, this change requires parliamentary approval and cannot be implemented through updated guidance alone. OFSI confirmed that all reforms not requiring legislative amendment took effect upon publication of the revised Enforcement and Monetary Penalties Guidance in February 2026, while the proposed increase to the statutory maximum will be introduced once the necessary legislative changes are enacted. 

OFSI launches an open call for evidence

On 16 February 2026, OFSI launched an open call for evidence on how the ownership and control test is operating in practice under the UK financial sanctions regime. The exercise seeks evidence and practical examples from firms, legal advisers and compliance professionals, particularly in relation to circumstances in which hypothetical control arises, the resulting compliance burden and legal risk, and whether existing legal concepts or typologies assist in assessing control.

The call for evidence closes on 13 April 2026. Responses may be submitted via an online form or by email. The Government intends to use the feedback to inform future policy development, with the aim of ensuring that the sanctions framework remains both effective and workable for legitimate business activity. 

Amendment to Personal Remittances General Licence

On 18 February 2026, OFSI amended its Personal Remittances General Licence (INT/2024/4761108) to expand the scope of permitted personal banking activities involving certain designated persons. The amendment authorises specified personal payments through institutions in the UK, EU/EFTA, US and Canada, subject to strict conditions and a cumulative monetary cap. The licence does not permit commercial transactions or activity beyond the defined personal remittance parameters. 

OFSI Prioritises Licence Applications 

On 19 February 2026, OFSI published new guidance explaining how it prioritises financial sanctions licence applications. The guidance outlines how OFSI categorises applications as high, medium or low priority, including consideration of factors such as humanitarian need, legal obligations, and risks to the integrity of the sanctions regime. The publication is intended to improve transparency around OFSI’s case management approach.

OFSI case study 

On 23 February 2026, OFSI published a blog highlighting practical compliance lessons from its £160,000 monetary penalty imposed on Bank of Scotland Plc for breaches of the Russia financial sanctions regime. The post uses the case to illustrate how sanctions controls operate in practice and what weaknesses can expose firms to the risk of breaching UK sanctions, which apply to conduct within the UK and to UK persons globally.

Key lessons include:

• Screening quality matters: The bank’s automated screening failed to match a designated person because of a spelling variation in the customer’s name, underscoring the importance of robust data configuration and using enriched screening tools where justified by risk.

• Automation alone isn’t enough: Firms need strong contingency procedures and clear escalation paths so staff know exactly when and how to raise potential sanctions issues, especially in higher-risk areas like PEPs.

• Training must be current: training should be regularly reviewed and updated to reflect changes in the geopolitical and regulatory landscape to ensure effective compliance.
• Voluntary disclosure helps: Prompt disclosure of a suspected breach can materially influence the outcome. OFSI rewards early and complete voluntary reporting with penalty discounts, and firms should act “as soon as practicable” in reporting.

OFSI emphasises that it looks at how well controls work in practice, not just whether they exist, and encourages firms to review their screening systems, escalation procedures, training and reporting frameworks in light of these lessons.

General Licences  

Maritime Mutual Wind Down General Licence (INT/2026/8893924), effective 24 February 2026 

This licence (INT/2026/8893924) permits UK insurers and UK insurance brokers to receive, process and transmit funds to or from Maritime Mutual Association Limited, Maritime Mutual Insurance Association (NZ) Limited and their subsidiaries in connection with insurance or reinsurance contracts agreed in writing before 24 February 2026. The licence also authorises activity reasonably necessary to cancel, terminate or otherwise wind down such arrangements, and allows relevant UK institutions to process associated payments. It expires at 23:59 on 9 April 2026. The licence imposes six-year record keeping requirements and does not authorise conduct beyond what is expressly permitted under the Russia Regulations.

PJSC Transneft Wind Down General Licence (INT/2026/8889196), effective 24 February 2026 

This licence (INT/2026/8889196) authorises persons to wind down or divest from transactions involving PJSC Transneft or its subsidiaries, including closing out positions, together with any activity reasonably necessary to give effect to that wind down. The licence also permits relevant UK institutions to support such activity and remains in force until 23:59 on 9 April 2026. It is subject to six-year record keeping obligations and does not permit activity that would otherwise breach the Russia Regulations.

Continuation of Business of Lukoil Bulgaria Entities General Licence (INT/2025/7895596), amended 10 February 2026 

OFSI’s General Licence INT/2025/7895596, originally issued on 14 November 2025 under the Russia (Sanctions) (EU Exit) Regulations 2019, permits certain activities necessary to support the continued operation and specified dealings involving Lukoil Neftochim Burgas AD and related Bulgarian subsidiaries, notwithstanding their designation under the Russia sanctions regime. The licence was amended on 20 November 2025 to expand the list of covered subsidiaries and further amended on 10 February 2026 to extend its expiry date to 13 August 2026. The February amendment did not alter the substantive permissions but prolonged the duration of the licence.

GLOBAL REGULATIONS/TOOLS UPDATE – USA 

Launch of Voluntary Self-Disclosure Portal 

On 6 February 2026, OFAC launched a new online Voluntary Self-Disclosure (VSD) Portal to provide a streamlined and secure method for reporting potential sanctions breaches. OFAC reiterated that qualifying voluntary self-disclosures are a significant mitigating factor and may result in up to a 50 percent reduction in the base penalty amount.

FinCEN launches sanctions whistleblower portal 

On 13 February 2026, the US Financial Crimes Enforcement Network (FinCEN) launched a dedicated online portal to receive confidential whistleblower tips relating to sanctions violations, as well as fraud and money laundering. The webpage provides information on eligibility, reporting procedures and potential award mechanisms under the US whistleblower programme, and is intended to strengthen detection and enforcement of financial crimes and sanctions breaches.

The PAIPA sanctions 

On 24 February 2026, the U.S. State Department announced the first-ever designations under the Protecting American Intellectual Property Act of 2022 (PAIPA), targeting a Russian cyber tools broker, its director and a UAE-based affiliate for their alleged involvement in the theft and sale of US trade secret exploits. PAIPA mandates the imposition of sanctions, including blocking measures and financial restrictions, against foreign persons engaged in significant trade secret theft that threatens US national security or economic interests. OFAC simultaneously designated the same parties under its cyber-related authorities, underscoring the US Government’s willingness to deploy IP-related sanctions tools alongside traditional financial sanctions frameworks.

CONCLUSION 

February’s developments reinforce that the scope and reach of the principal international sanctions regimes are becoming ever broader, extending across new sectors, actors and compliance touchpoints. At the same time, the consequences of breaching those regimes are becoming increasingly serious. In the UK, this is reflected in OFSI’s updated enforcement guidance and its proposed increase to the UK Statutory Maximum Penalty, signalling a more robust and structured approach to sanctions breaches.

As scrutiny intensifies, firms should ensure that their sanctions controls remain proportionate, well-documented and capable of withstanding regulatory review. MR’s monthly sanctions update will continue to monitor these developments and key enforcement trends shaping the global sanctions landscape.

This blog post is not offered, and should not be relied on, as legal advice. You should consult an attorney for advice in specific situations. 

Investment arbitration has become a central feature of the international legal framework governing foreign investment. It provides investors with a direct mechanism to bring claims against host states for breaches of treaty obligations, outside the domestic courts of the host state. Used prudently, it can act as a practical system of legal protections that operates alongside contracts and domestic law.

This first blog in a two-part series provides a practical overview of investment arbitration and the core protections typically available to investors under investment treaties.

The Nature of Investment Arbitration 

Investment arbitration allows a foreign investor to bring claims directly against a host state before an independent international tribunal. The state’s consent to arbitration is given in a contract with the investor in an international treaty concluded with the investor’s home state or with multiple states.

When an investor initiates arbitration under the investment treaty, a binding arbitration agreement is formed. This structure enables private parties to enforce obligations grounded in public international law against a state, as opposed to the traditional system where public international law principles could only be enforced by states, against states.

Who May Bring Claims and Against Whom

Investment treaties limit standing to qualifying investors who are nationals. For individuals, nationality is usually determined by citizenship. For companies, nationality is typically based on place of incorporation or seat, though some treaties impose additional requirements such as substantial business activity.

These definitions are critical. Jurisdictional objections frequently turn on whether the claimant qualifies as an investor under the treaty with ownership structures, control, and timing often closely scrutinised.

Depending on the terms of the treaty, claims can be brought against states for governmental action, whether through their ministries, regulators, courts, and other entities exercising governmental authority. Conduct by state-owned enterprises may also be attributable to the state in certain circumstances.

What Constitutes a Protected Investment

Treaties define the investments they protect. Most adopt a broad, asset-based definition inter alia covering shares, loans, contractual rights, concessions, licences, and intellectual property.

Tribunals nevertheless assess whether the alleged investment meets objective criteria, particularly where treaties refer to contribution, duration, and risk. Purely commercial transactions or short-term sales may fall outside the scope of protection.

The way an investment is structured, financed, and documented therefore has legal significance. Economic exposure alone cannot guarantee treaty protection.

Core Substantive Protections

While treaty language varies, most investment treaties include a core set of substantive protections that define permissible state conduct.

Protection Against Expropriation

Expropriation, simply, means the taking of property. Treaties generally prohibit expropriation except where it is for a public purpose, carried out in accordance with due process, non-discriminatory, and accompanied by compensation.

Expropriation may be direct, such as formal nationalisation, or indirect, where measures substantially deprive the investor of the use or value of the investment through indirect measures such as regulatory action, licence withdrawal, and the like, depending on their effect on the investor.

Fair and Equitable Treatment

Fair and equitable treatment is among the most frequently invoked standards. It protects investors against arbitrary, abusive, or fundamentally unfair conduct by the host state in which the investment has been made.

Tribunals have interpreted this standard to include respect for legitimate expectations, transparency, consistency, due process, and good faith. While modern treaties increasingly seek to define or limit this obligation, it remains a central protection against egregious conduct by the state.

Full Protection and Security

This standard obliges states to exercise due diligence in protecting investments. While historically focused on physical security, it has in some cases been extended to legal and institutional protection, particularly where systemic failures undermine the investment.

Most Favoured Nation (“MFN”) and National Treatment

Investment treaties often include the non-discrimination standards of MFN and national treatment as protections for investors.

National treatment obliges the state to treat foreign investors no less favourably than domestic investors in like circumstances. Claims often arise where regulatory measures, licensing regimes, or enforcement practices disadvantage foreign investors relative to local actors.

Most favoured nation treatment, on the other hand, requires the state to treat investors from the claimant’s home state no less favourably than investors from any third state. In some cases, this clause has been invoked to access more favourable protections found in other treaties, though this approach is increasingly restricted by treaty drafting. Tribunal have also diverged on whether such a reading of the MFN clause is permissible.

Both standards involve a contextual comparison, and differential treatment may be justified by legitimate regulatory objectives.

Procedural Protections and Access to Arbitration

Treaties provide investors with access to international arbitration, commonly under ICSID or UNCITRAL rules. This offers neutrality, enforceability, and insulation from domestic political pressures.

Treaties oftentimes have procedural requirements for the access to arbitration. Cooling-off periods, notice requirements, limitation periods, and jurisdictional thresholds must be respected. Failure to comply can result in dismissal regardless of the merits.

Conclusion

Investment arbitration operates alongside contracts and domestic remedies and in some cases contractual obligations can be elevated to treaty disputes (through a provision often referred to as an umbrella clause). However, in most instances, treaty claims are based on breaches of international law, not merely contractual non-performance. For most cases, the state’s conduct must result in a breach of treaty standards.

Investors should seek strategic input early as in their disputes choices made in domestic forums can nonetheless affect treaty rights as treaty protections are only available if the investor and investment fall within the treaty’s scope. That determination often depends on decisions made at the investment stage.

Understanding and prudently leveraging investment arbitration as a legal framework, rather than an emergency remedy, gives investors a further tool to manage sovereign risk in cross-border investments. In the upcoming article in this series, we will explore what considerations investors need to consider while structuring their investments.

This blog post is not offered, and should not be relied on, as legal advice. You should consult an attorney for advice in specific situations. 

KEY DEVELOPMENTS 

• UK, US and EU sanctions developments following unrest in Iran: The UK confirmed it is reviewing the scope of its Iran sanctions response following reports of fatalities and mass arrests linked to unrest beginning in late December 2025; ministers indicated that existing designations remain in force and that further measures may be introduced. A House of Commons Library briefing outlined planned UK sanctions targeting sectors including finance, energy, transport and software, and referenced the October 2025 “snapback” of UN sanctions on Iran’s nuclear and ballistic missile programmes. The US and EU also moved in parallel, with Washington imposing multiple sanctions targeting Iranian oil shipping networks, senior officials and digital asset platforms linked to repression and sanctions evasion, and EU governments preparing a new package of human rights-based measures. 

• Sanctions evasion and enforcement challenges: Investigative reporting highlighted the limits of unilateral sanctions, revealing that a UK-designated Iranian businessman continues to control substantial European real estate assets outside the scope of EU sanctions; the case illustrates how complex ownership structures and divergence between UK and EU regimes can complicate asset freeze enforcement. 

• Russia-related energy and sanctions developments: The EU formally adopted a phased ban on imports of Russian gas under the REPowerEU strategy, marking a significant escalation in energy-related sanctions. Western measures also continued to drive the forced divestment of Russian energy assets overseas. In the UK, enforcement activity remained active, with criminal proceedings scheduled in the luxury goods sector, amendments to the UK Sanctions List, and a court judgment confirming that compliance with Russia sanctions can provide a lawful basis for refusing services. 

• Regional and cross-sector sanctions actions: The US imposed sanctions targeting a Costa Rica-based cocaine trafficking and money laundering network, and separate measures against Hamas-linked entities in Gaza that are operating through purported humanitarian and nonprofit structures.

• Global regulatory and general licence updates: The UK moved to a single authoritative sanctions list, discontinuing updates to OFSI’s consolidated  OFSI also revised the Russian oil price cap and imposed a monetary penalty on a UK bank for sanctions screening failures. In the US, OFAC issued a new general licence authorising narrowly defined transactions involving Venezuelan-origin oil, subject to detailed conditions and reporting requirements. 

GLOBAL SANCTIONS

IRAN 

• On 13 January 2026, the UK government confirmed it is reviewing the scope of its sanctions response to developments in Iran following reports of fatalities and mass arrests linked to unrest that began in late December 2025. In a statement to Parliament, ministers indicated that existing UK sanctions targeting Iranian individuals and entities linked to human rights abuses remain in force, and that additional designations may be considered depending on further developments. The update reflects continued UK use of its autonomous Iran sanctions regimes, including asset freezes and travel bans, in response to assessed conduct by Iranian state-linked actors. 

• A House of Commons Library research briefing published on 19 January 2026 outlines the UK and international response to widespread protests in Iran that began in late December 2025. The briefing notes that, alongside diplomatic condemnation of Iranian state violence, the UK Government has indicated it plans to introduce further sanctions targeting sectors including finance, energy, transport and software in response to human rights abuses and the regime’s actions. As at mid-January 2026, the UK had 286 individuals and 260 organisations on its Iran sanctions lists, including entities linked to the Islamic Revolutionary Guard Corps and groups deployed against protesters. The briefing also references the UK’s October 2025 decision, with France and Germany, to trigger “snapback” of UN sanctions against Iran’s nuclear and ballistic missile programmes, reinstating broad multilateral measures that apply across UN member states. 

• On 23 January 2026, the US imposed sanctions on nine vessels and their owners accused of transporting hundreds of millions of dollars’ worth of Iranian oil to foreign markets through a “shadow fleet” of older tankers flagged in jurisdictions including Palau and Panama. OFAC stated that the measures were linked to Iran’s ongoing crackdown on nationwide protests and its unprecedented internet shutdown, which began on 8 January 2026 to suppress information sharing and conceal human rights abuses. US officials described the sanctions as targeting a critical revenue source used to fund domestic repression, underscoring Washington’s increasing focus on oil shipping networks that enable Iran to evade international restrictions and generate illicit export income. 

• On 26 January 2026, investigative reporting by the Financial Times revealed that Ali Ansari, an Iranian businessman designated by the UK for allegedly financing the Islamic Revolutionary Guard Corps, controls a European real estate portfolio valued at approximately €400 million through a network of offshore holding companies. While UK authorities froze Ansari’s London assets following his designation, the investigation found that he is not currently subject to EU sanctions, allowing him to retain ownership of high-value properties in Spain, Germany and Austria, including hotels, a golf resort and a shopping centre. The findings, based on corporate filings across multiple jurisdictions, illustrate how complex ownership structures and gaps between UK and EU sanctions regimes can limit the practical reach of unilateral sanctions measures and complicate asset-freeze enforcement beyond national borders. 

• 27 January 2026: EU governments are expected to approve a package of new sanctions against Iranian individuals and entities in response to the Iranian government’s violent crackdown on nationwide protests that began in late December 2025. The measures are anticipated to be adopted under the EU’s global human rights sanctions framework and are likely to target those responsible for or linked to the repression, including travel bans and asset freezes, though Iran’s Islamic Revolutionary Guard Corps is not expected to be added to the list at this stage. The sanctions push reflects mounting EU concern over serious human rights abuses in Iran, complementing existing EU restrictions related to Iran’s nuclear and proliferation activities. 

• On 30 January 2026, the US imposed new sanctions against Iranian officials and financial networks linked to the regime’s violent crackdown on nationwide protests. OFAC designated Iran’s Interior Minister Eskandar Momeni Kalagari and several senior Islamic Revolutionary Guard Corps and law enforcement commanders for their roles in repression and human rights abuses. The US also sanctioned Babak Morteza Zanjani, a prominent businessman accused of laundering funds for the regime, together with two UK-registered digital asset exchanges, Zedcex Exchange Lt and Zedxion Exchange Ltd., which allegedly processed significant volumes of IRGC-linked transactions. The US Treasury described the move as its first designation of a digital asset exchange connected to Iran, highlighting the growing US focus on the use of cryptocurrency platforms in an effort to support sanctions evasion as well as regime financing. 

KAZAKHSTAN 

• On 28 January 2026, Kazakhstan’s government formally submitted a bid to US authorities to acquire stakes held by Russian oil producer Lukoil in major Kazakh energy projects, including interests in the Karachaganak and Tengiz oilfields and the Caspian Pipeline Consortium, according to a report in Global Banking & Finance Review. The move comes as Lukoil, which was sanctioned by the US in October 2025, is required to divest its overseas assets under the terms of the sanctions regime and associated wind-down licence, with a deadline of 28 February 2026 for sales. Kazakhstan’s bid will require approval from the US Office of Foreign Assets Control (OFAC) given the sanctions framework under which asset disposals must take place. The involvement of a sovereign state in a bid for sanctioned foreign energy assets reflects how sanctions are reshaping global energy ownership and investment dynamics, particularly in Central Asia where key energy infrastructure is jointly operated by Western and regional partners.

RUSSIA

• 12 January 2026: The UK Crown Prosecution Service has scheduled a criminal trial in January 2028 against Hauser & Wirth’s UK subsidiary and a London-based art shipping company for alleged breaches of the UK’s Russia sanctions regime. Prosecutors allege that the gallery made a high-value artwork available in 2022 to a person “connected with Russia,” in contravention of the UK ban on the supply of luxury goods, including artwork, to such persons under the Russia (Sanctions) (EU Exit) Regulations. The alleged conduct relates to a work by George Condo provided between April and December 2022, a period after the UK introduced a prohibition on exporting luxury items valued over £250 to Russia following the invasion of Ukraine. A procedural hearing is set for 5 May 2026, when the defendants are expected to enter pleas, and the trial itself is scheduled for January 2028 at Southwark Crown Court. This case marks a significant test of sanctions enforcement in the UK luxury goods sector and reflects intensified scrutiny of corporate compliance with sanctions, particularly where luxury goods and art market participants are concerned. 

• In Migita and others v JP Morgan [2026] 1 WLUK154, a judgment handed down on 16 January 2026, the Central London County Court dismissed discrimination claims arising from the bank’s refusal to onboard three Russian-born clients in 2023. The court accepted that the decision was driven by compliance with EU Russia sanctions, specifically the deposit restrictions under Regulation 833/2014, which prohibit EU-regulated banks from accepting deposits exceeding €100,000 from Russian nationals unless an exemption applies. Although the claimants alleged that the refusal amounted to unlawful discrimination based on nationality, the court found that onboarding would have been prohibited under the sanctions regime in any event. The case confirms that sanctions compliance can provide a lawful basis for refusing services, while highlighting the importance of clear internal reasoning and accurate external communications when sanctions restrictions are relied upon.

• On 16 January 2026, the UK Government issued an update to the UK Sanctions List under the Russia sanctions regime, amending the entry for John Michael Ormerod. The individual remains designated and continues to be subject to an asset freeze and trust services sanctions. 

• On 26 January 2026, the Council of the European Union formally adopted legislation introducing a phased ban on imports of Russian gas, covering both pipeline gas and liquefied natural gas. The measure forms part of the EU’s REPowerEU strategy to end dependence on Russian energy supplies. The ban will be implemented gradually, with initial restrictions taking effect shortly after the regulation enters into force and transitional arrangements applying to certain existing contracts to mitigate market disruption. A full prohibition on Russian LNG imports is expected from early 2027, with pipeline gas imports to be phased out by autumn 2027. Member states will be required to verify the origin of gas imports, notify authorities of any remaining Russian supply contracts, and submit national diversification plans by 1 March 2026. The regulation will apply directly across all EU member states following publication in the Official Journal. 

• 28 January 2026: Western sanctions imposed on Russia’s energy sector in late 2025 are accelerating the forced unwind of major Russian oil companies’ overseas footprints, with Lukoil now marketing an estimated $22 billion portfolio of international assets across upstream production, refining, retail fuel networks, and joint venture stakes. According to Reuters, Chevron is in talks with Iraq over West Qurna-2, one of the world’s largest oilfields where Lukoil holds a 75% stake and is seeking improved contract terms before taking over operations, highlighting how sanctions-driven divestments are reshaping access to strategic energy infrastructure. Reports in early January 2026 also pointed to a potential bid led by Chevron alongside private equity firm Quantum Energy Partners, potentially splitting Lukoil’s international assets between them as restrictions on financing and operations continue to narrow Lukoil’s ability to maintain foreign holdings. 

SOUTH KOREA  

• 26 January 2026: The US has announced plans to raise tariffs on imports from South Korea to 25%, up from the current 15%, citing delays in Seoul’s implementation of a bilateral trade agreement reached in 2025. The proposed increase would apply across a broad range of goods subject to the US “reciprocal tariff” framework, including automobiles, pharmaceuticals, lumber and other manufactured products. South Korea stated that it had not received formal notification of the tariff increase and has requested urgent consultations with Washington. The trade deal, which includes a US$350 billion South Korean investment commitment in the US, was submitted to South Korea’s National Assembly in November and is still under review. Market reaction was initially negative, particularly for Korean automotive manufacturers, though equity markets later recovered amid uncertainty as to whether the tariff increase will ultimately be implemented. 

COSTA RICA  

• On 22 January 2026, the US imposed sanctions on a major Costa Rica-based cocaine trafficking and money laundering network responsible for transporting multi-ton quantities of cocaine from Colombia through Costa Rica to the United States and Europe. OFAC designated Luis Manuel Picado Grijalba, described as one of the Caribbean’s most prolific traffickers, along with his brother, key enforcers, and five Costa Rica-based entities used to facilitate drug shipments and launder proceeds. The designated entities include businesses operated by family members, such as fishing, investment, and commercial companies, as well as a beauty salon alleged to have served as a front for laundering illicit funds and notarising fraudulent transactions. The action underscores growing US focus on Costa Rica’s role as a transshipment hub and reflects coordinated efforts with the DEA and Costa Rican authorities to dismantle the financial infrastructure supporting regional narcotics trafficking.

GAZA  

• On 21 January 2026, the US imposed new sanctions targeting Hamas’s covert support infrastructure, including nonprofit organizations in Gaza and an internationally active front group linked to Hamas’s political outreach abroad. OFAC designated six Gaza-based entities that purported to provide humanitarian and medical services but were found to be integrated into Hamas’s military wing and used to divert donor funds to support terrorist operations. The US also sanctioned the Popular Conference for Palestinians Abroad, described as a Hamas-controlled organization involved in organizing international flotillas and expanding Hamas’s influence within the Palestinian diaspora, alongside a UK-based senior official affiliated with its leadership. The designations reflect a growing focus on the exploitation of civilian and charitable structures to finance terrorism while posing heightened compliance risks for the humanitarian and nonprofit sectors. 

GLOBAL REGULATION/ TOOL UPDATES 

On 28 January 2026, the UK moved from a dual-list system to a single authoritative list for sanctions designations. Previously, UK designations were published in both the UK Sanctions List (maintained by the FCDO) and OFSI’s Consolidated List of Asset Freeze Targets. Following the change, the OFSI Consolidated List and its search tool has stopped being updated, and all new UK designations, amendments and de-listings are now being published only on the UK Sanctions List. 

General Licenses  

On 15 January 2026, OFSI revised General Licence INT/2024/4423849 governing the provision of maritime transport and related services for Russian crude oil and oil products where transactions comply with the oil price cap. The revised licence lowers the cap from USD 47.60 to USD 44.10 per barrel, with the new threshold applying from 23:01 GMT on 31 January 2026. To facilitate an orderly transition, OFSI has included a temporary wind-down period for contracts entered into before that time which meet the previous cap, allowing such activity to continue until 22:59 BST on 16 April 2026. OFSI also updated its Financial Sanctions FAQs and the Maritime Services Ban and Oil Price Cap industry guidance to reflect the revised cap. 

On 26 January 2026, the UK’s Office of Financial Sanctions Implementation (OFSI) imposed a £160,000 monetary penalty on Bank of Scotland plc, part of Lloyds Banking Group, for  breaching the UK’s Russia sanctions regime. The penalty follows an incident in February 2023 in which the bank opened and operated a personal current account for Dmitrii Ovsiannikov, a Russian national and former senior official who remains on the UK Sanctions List. Of the 24 payments processed through the account, totaling approximately £77,000, OFSI determined that the bank had made funds available to a designated person in contravention of financial sanctions prohibitions. The breach occurred because the account was opened using a British passport with a spelling variation of Ovsiannikov’s name, which was not reflected in the bank’s automated sanctions screening database, resulting in the initial failure to flag the customer as a designated person. The account was later identified during enhanced screening, the restrictions were applied, and the issue was voluntarily reported to OFSI by the bank, which contributed to the 50% reduction in the penalty from its original level. Lloyds has stated that it has strengthened its sanctions controls and screening systems following the incident. This case underscores the importance of robust name matching and screening processes, including handling of name variants and politically exposed person checks, for UK financial institutions subject to financial sanctions requirements. 

On 29 January 2026, OFAC issued General License No. 46 under the US’s Venezuela Sanctions Regulations (31 CFR part 591), authorising certain transactions ordinarily incident to the lifting, export, sale, transport, and refining of Venezuelan-origin oil by established U.S. entities, including dealings involving PdVSA and other blocked Venezuelan state-linked entities. The authorisation is subject to strict conditions, including that contracts must be governed by US law with dispute resolution in the United States, and that any payments to blocked persons must be made into designated Foreign Government Deposit Funds. The licence permitsrelated shipping, logistics, marine insurance, and commercially reasonable crude or product swap arrangements, while prohibiting non-commercial payment terms, digital currency payments, transactions involving Russia, Iran, North Korea, Cuba, or certain China-linked joint ventures, and any dealings with blocked vessels. The licence also imposes detailed reporting requirements for any onward supply of Venezuelan oil outside the United States, underscoring continued regulatory scrutiny of sanctioned energy-sector activity.  

CONCLUSION 

We will track these developments and, by way of our monthly sanctions update, we will continue to offer timely insight into international sanctions measures, regulatory changes and enforcement trends shaping the global sanctions landscape. 

This blog post is not offered, and should not be relied on, as legal advice. You should consult an attorney for advice in specific situations.   

Retail media is no longer a niche marketing tool. These days, it has become a defining feature of modern retail environments, ushering in a new era where physical space and digital reach operate hand in hand. With Westfield Rise launching its global retail media platform, complete with hundreds of digital screens across flagship malls, Simon Media & Experiences expanding nationwide, Cineplex creating and selling advertising on digital screens in various high-traffic locations across Canada, and the retail media network owned by the Co-op Group in the UK, major landlords are now functioning as both property operators and media companies. Their centers are effectively becoming full-scale media networks, capable of delivering targeted content, sponsorships, programmatic advertising, and immersive shopper engagement.

For tenants, this evolution has profound implications. Digital screens, interactive displays, and AI-enhanced content strategies increasingly shape customer impressions before a shopper even steps inside a store. Yet in many organizations, the people who control the media infrastructure and the people who negotiate leases operate in separate silos. The leasing team handles square footage and rent; the media team owns screen locations, ad inventory, data collection tools, and content policies.

This divide can be confusing, but it can also be a source of significant opportunity for tenants who understand how to navigate it.

From Challenge to Opportunity 

This separation between leasing and media operations may initially seem like a challenge, but savvy tenants—guided by experienced brokers and counsel—are increasingly recognizing it as an opportunity. When engaged early, a landlord’s media team brings powerful capabilities to the table: brand storytelling, digital visibility, property-wide amplification, and integrated campaigns that extend far beyond the storefront itself.

By approaching retail media proactively rather than reactively, tenants can secure visibility, protect their brand, and capitalize on the growing sophistication of property-wide media networks. What first appears to be a point of friction often becomes a meaningful advantage when the conversation begins early and the tenant’s strategy is integrated into both leasing and media planning.

Early engagement also prevents tenants from being blindsided later. Without proactive negotiation, tenants may find their beautiful new storefront framed by competing ads or incongruent content—an outcome that is both jarring and avoidable.

For landlords, early coordination between leasing and media divisions enhances the guest experience, drives higher media performance, and minimizes friction in lease negotiations. In other words, collaboration turns retail media into a strategic asset for both sides. At the same time, today’s consumers increasingly crave real-world engagement: authentic, tactile experiences that break through digital fatigue. The rapid rise of in-store cafés and hospitality-style lounges illustrates this shift, offering moments of conversation, comfort, and even curated sensory experiences that draw people deeper into the physical environment.

Why Retail Media Is Surging Now

For years, retail media was synonymous with e-commerce and big-box operators who mastered data-driven advertising at scale. But destination retail centers—malls, lifestyle centers, entertainment districts—are now positioned to dominate the next chapter.

A confluence of forces explains why:

Post-pandemic consumer behavior—IRL!. After years online, shoppers are gravitating toward experiences that happen in real life.

AI-powered marketing. Brands need environments where digital and physical touchpoints reinforce one another.

High-traffic destinations. Major malls already function as gathering spaces; retail media simply unlocks their value as communication platforms.

The rise of experiential retail. Consumers increasingly expect more than a transactional visit. Coffee bars (as referenced above), children’s play zones, immersive activations, and new concepts like Simon’s planned “Netflix Houses” underscore this shift. These venues blend entertainment and retail through mini-golf, VR experiences, themed dining, and branded event spaces—driving foot traffic while deepening emotional connection to the property.

Westfield Rise, Simon Media, and Brookfield Malls exemplify the shift. Their networks transform static common areas into dynamic, data-rich environments—modern media channels that complement traditional retail leasing.

Why Media Rights Now Belong in the LOI

Historically, media rights were an afterthought, often addressed only after the lease was drafted. That approach is no longer viable.

By the time a lease reaches a tenant’s inbox, a landlord’s media policies are usually fixed, screen placements are installed, and category restrictions may already be in effect. Without addressing these issues earlier, tenants may lose key protections or opportunities.

For this reason, the Letter of Intent (LOI) has become the critical stage for shaping media-related terms. Addressing these points upfront preserves leverage and ensures that the physical premises and surrounding digital environment support the tenant’s brand.

Key areas to negotiate at the LOI stage include:

Control of Nearby Screens: The screens immediately adjacent to a tenant’s premises can significantly influence brand perception. LOIs should clarify:

• Who controls those screens
• Whether the tenant has the right to display its own content
• Whether competitor ads can be blocked
• Whether the tenant has approval or veto rights

Digital adjacency is the new storefront visibility; tenants should treat it with equal seriousness.

Content Standards and Category Restrictions. Without negotiated parameters, a tenant may be surprised to find its storefront next to visuals that clash with its brand identity or customer experience. The LOI should establish baseline content policies to prevent undesirable or conflicting placements.

Participation in—or Exclusion From—the Media Network. Some brands want guaranteed exposure within a property’s media program, while others prefer to stay out of the network altogether to avoid mixed messaging or brand dilution. The LOI should make this preference unmistakably clear, specifying whether the tenant intends to be included or to opt out, whether any fees apply to participation, and what opportunities may exist for seasonal placements or co-branded campaigns. Addressing these points upfront ensures the media strategy aligns with the tenant’s broader marketing objectives and avoids surprises once the lease is drafted.

Future-Proofing Technology Rights. Retail technology evolves at a rapid pace, and today’s state-of-the-art display can become outdated surprisingly quickly. To stay competitive, tenants should ensure the LOI preserves enough flexibility to upgrade their digital installations as needed, integrate emerging technologies into the store environment, and avoid repetitive or burdensome approval processes that slow innovation. Thoughtful future-proofing prevents operational bottlenecks and allows tenants to keep pace with technological advancements throughout the life of the lease.

Data, Privacy, and Cybersecurity Considerations. Modern retail media networks often collect analytics through Wi-Fi tracking, cameras, sensors, or other tools. Tenants must understand:

• What data is gathered
• How it is used and who it is shared with
• Consumer disclosure obligations
• Cybersecurity safeguards
• Liability allocations under privacy laws

Given the pace of regulatory change, proactive clarity here is essential.

A Summary Media Rights Exhibit: A concise media exhibit attached to the LOI—covering screen control, tenant visibility rights, content standards, and data responsibilities—creates alignment early and prevents disputes during lease negotiation.

The Broker’s Evolving Role

Brokers increasingly serve as the essential bridge between a landlord’s leasing machinery and its media operations. As retail media becomes more integrated into the tenant experience, the most effective brokers are those who can spot—often before anyone else—whether a property operates a media network and how that network may affect visibility, brand adjacency, and overall tenant strategy. They know to ask for media maps, screen locations, and content policies early, and they understand how these details can influence everything from customer flow to competitive positioning.

This deeper literacy allows brokers to anticipate issues such as competitor ads appearing near a tenant’s storefront or missed opportunities for brand amplification. It also enables them to weave media considerations directly into the LOI, ensuring the document reflects not only the physical terms of occupancy but also the digital context that surrounds the premises.

In this way, the broker becomes more than a dealmaker—they become the quarterback of media negotiations, shaping outcomes that can materially enhance a tenant’s visibility and success within the center.

A Note for Landlords

Landlords and their media affiliates gain when they coordinate early and offer tenants a cohesive understanding of the property’s media infrastructure. Transparency builds trust, improves media monetization, and strengthens the broader tenant ecosystem. As media networks grow more sophisticated, consistency between leasing and media operations will become a defining competitive advantage.

Conclusion: Leasing in the Age of Screens

Retail leasing today includes two parallel environments: the physical space a tenant occupies and the digital landscape that surrounds it. As media networks like Westfield Rise and Simon Media continue their rapid expansion, the screens next to a store may influence customer behavior as strongly as the store design itself.

For tenants, the takeaway is simple: media rights are now a fundamental part of real estate strategy. Addressing them early—especially at the LOI stage—ensures control, visibility, and brand protection in an increasingly digital retail world.

Handled thoughtfully, retail media enhances storytelling, elevates customer experience, and differentiates brands in ways that traditional leasing alone cannot. In today’s environment, success depends not just on the space you lease, but on the screens that frame it.

This blog post is not offered, and should not be relied on, as legal advice. You should consult an attorney for advice in specific situations.

An opt-out collective action on behalf of homebuyers is being prepared for filing in Q1 2026 in relation to the UK housebuilding sector, with Mark McLaren seeking certification as class representative. The proposed claim follows an investigation by the Competition and Markets Authority (“CMA”) into suspected potentially anti-competitive conduct by seven major housebuilders in connection with the sale of new-build homes across Great Britain.

The CMA investigation was closed following the acceptance of binding, forward-looking commitments. Importantly, the CMA did not make any finding of infringement, and the commitments were offered and accepted without any admission of liability.

Background

The proceedings have not yet been filed. However, claimant-side announcements indicate that the proposed claim is intended to build on a CMA investigation opened in February 2024 into suspected breaches of the Chapter I prohibition of the Competition Act 1998, which prohibits agreements, decisions and concerted practices between undertakings which have as their object or effect the restriction, distortion or prevention of competition within the UK and which affect trade within the UK.

The investigation concerned seven of the largest housebuilders operating in Great Britain — Barratt Redrow, Bellway, Berkeley, Bloor, Persimmon, Taylor Wimpey and Vistry — which the CMA suspected may have engaged in exchanges of competitively sensitive information during the period from January 2022 to February 2024.

The collective proceedings are expected to seek damages on behalf of homebuyers on an opt-out basis, as is typical for claims of this nature.

Commitments vs infringement  

The CMA’s investigation did not culminate in a statement of objections or an infringement decision. Instead, it was closed following the acceptance of commitments under which the housebuilders agreed to cease the conduct giving rise to the CMA’s concerns and to implement certain forward-looking measures.

That distinction matters.

• An infringement decision involves a formal finding by a competition authority that competition law has been breached, following a full investigation. Such decisions can be relied upon as binding findings of liability in subsequent “follow-on” damages claims.

• By contrast, the acceptance of commitments brings an investigation to a close without any finding of infringement. Commitments are voluntarily offered, forward-looking in nature, and are accepted expressly without determining whether any unlawful conduct occurred. They do not establish liability and do not bind the court or tribunal in private damages proceedings. Any claim relying on commitments must therefore proceed as a stand-alone action, with infringement, causation and loss proved afresh.

Stand-alone rather than follow-on

The absence of an infringement decision means that any collective proceedings are likely to be framed as a stand-alone claim. The consequences are significant.

In a stand-alone action, the burden rests squarely on the claimant to establish every element of liability and loss from first principles. This includes defining the relevant markets, proving the existence of anti-competitive conduct, demonstrating its effects, constructing a credible counterfactual, and establishing causation and quantum of loss.

The fact that the housebuilders volunteered commitments does not give rise to any presumption of breach. Commitments are accepted without any finding or admission of infringement and do not shift the burden of proof in subsequent private damages claims.

Scope and defendants

At this stage, the contours of any eventual claim remain unclear. Public statements suggest that the claim may initially focus on the seven housebuilders that were subject to the CMA investigation. However, that position may evolve as the claim progresses towards filing.

It also remains to be seen whether the proposed class representative will seek to allege market-wide effects extending beyond the conduct examined by the CMA, potentially drawing in additional market participants based on alleged spill-over effects. Any such approach would materially increase complexity at the certification stage, sharpening issues around commonality, causation and proof of loss — particularly given the CMA’s express statement that its investigation did not extend to certain aspects of housebuilding activity.

Depending on how any claim is framed, limitation and temporal scope may also become contested issues, particularly given that the CMA’s investigation was confined to conduct alleged to have taken place during a relatively short, defined period between January 2022 and February 2024.

Certification

It may be tempting to assume that certification will follow as a matter of course because the proposed claim comes on the heels of a CMA investigation. That assumption would be misplaced, particularly in a stand-alone case.

There is now a substantial body of authority emphasising that certification is not a rubber-stamping exercise, especially in stand-alone cases. The Tribunal will scrutinise all aspects of the application, including: (i) the proposed common issues; (ii) the loss methodology; (iii) the credibility and class-wide applicability of the counterfactual; (iv) the suitability of the proposed class representative; (v) the funding arrangements; and (vi) the proposed approach to damages distribution.

Another central issue is likely to be the definition of the proposed class, and whether it is said to encompass all purchasers of new-build homes over a defined period, or only purchasers of properties developed by the investigated housebuilders. Geographic and temporal distinctions may also be required, given the localised nature of housing markets and the timing of the alleged conduct.

These questions go directly to commonality and manageability. Housing markets are inherently local. Pricing, incentives and sales practices vary materially by location and over time. Any attempt to aggregate claims across developments and regions will require an economic methodology capable of accommodating that variation without collapsing into individualised assessment.

Funding and strategic pressure

The claim is reportedly supported by third-party litigation funding from Burford Capital, a well-established funder in the UK collective actions market. As with other funded opt-out claims, the presence of third-party funding introduces an additional set of commercial incentives, including funder economics and return thresholds, which can shape litigation strategy and settlement dynamics.

Conclusion

The proposed opt-out collective action against UK housebuilders is likely to be one of the most closely watched cases of 2026.

The proximity of the proposed claim to the CMA’s decision is not coincidental. It reflects a now well-established trend in UK competition litigation in which regulatory scrutiny — even where it stops short of an infringement decision — is treated as a potential springboard for large-scale private damages claims. Earlier collective proceedings have drawn on market studies, sectoral reviews and regulatory investigations as part of the factual matrix relied upon at certification.

The Tribunal has accepted that such material can form part of the relevant background and may assist in demonstrating that a claim is not speculative. However, regulatory concern is not a substitute for pleaded infringement, and it does not relieve a class representative of the obligation to advance a coherent and workable case capable of clearing the demanding certification gateway.

For the housebuilders, the proposed claim comes at a time of sustained regulatory and policy pressure on the sector, including fire safety remediation obligations, the self-remediation contract and the forthcoming Building Safety Levy. It underscores the cumulative pressures facing the industry and the environment in which any litigation will be defended.

This blog post is not offered, and should not be relied on, as legal advice. You should consult an attorney for advice in specific situations.

California lawmakers continue to expand workplace protections, increase enforcement authority, and raise the stakes for noncompliance. As we turn the page on 2025, employers face a combination of new statutory obligations, expanded employee rights, and enhanced penalties, along with several laws that have already taken effect but now require immediate attention.

Below, we summarize the most significant developments, explain the policy goals behind them, and outline practical steps employers should take to reduce risk and stay compliant.

WAGE INCREASES & COMPENSATION THRESHOLDS

Statewide and Local Minimum Wage Increases

California’s minimum wage framework continues to reflect the Legislature’s focus on cost-of-living pressures and income equity. Effective January 1, 2026, the statewide minimum wage increases to $16.90 per hour, which automatically raises the minimum annual salary required for most exempt employees to $70,304.

At the same time, many local governments—particularly in major metropolitan areas—have adopted higher minimum wages to address regional housing and living costs. Employers must comply with the highest applicable wage based on where work is performed, not where the business is based. Importantly, some of these local jurisdictions implement minimum wage increases on a midyear schedule (often July 1), rather than January 1, requiring employers to monitor local updates throughout the year.

Notable local rates include:

• City of Los Angeles: $17.87/hour (general); $22.50/hour for hotel workers
• Los Angeles County (unincorporated): $17.81/hour
• Santa Monica: $17.81/hour (non-hotel); $22.50/hour (hotel)
• West Hollywood: $20.25 (nonhotel); $20.22/hour (hotel)
• San Francisco: $19.18/hour
• San Diego: $17.50/hour

Why this matters: Wage errors—especially in high-cost jurisdictions—remain one of the most common sources of class and representative litigation. Even small discrepancies can quickly compound across pay periods and employees.

What employers should do:

• Verify wage rates by employee work location
• Reassess exempt classifications tied to salary thresholds (as well as other requirements)
• Ensure payroll systems and budgets reflect local requirements

HOSPITALITY INDUSTRY: LOS ANGELES HOTEL WORKER ORDINANCE 

Hotel Worker Training, Wage & Notice Requirements 

After prolonged legal challenges, the City of Los Angeles’ Hotel Worker Training Ordinance is now fully in effect as of September 8, 2025. The ordinance reflects the City’s broader effort to regulate working conditions in the hospitality industry by mandating training standards, higher wages, benefit requirements, recordkeeping, and employee notices for covered hotels.

Unlike many employment laws that primarily require policy updates, this ordinance demands operational changes, particularly around training and staffing practices.

Why this matters: Enforcement is expected to be active, and noncompliance can trigger administrative penalties and litigation exposure.

What employers should do:

• Confirm whether your property is covered
• Implement required training and documentation
• Review notices, postings, and record-retention protocols

EMPLOYEE NOTICES, RECORDS & CONTRACTS

Workplace “Know Your Rights” Notice (SB 294)

SB 294 reflects California’s increasing emphasis on transparency and employee awareness of workplace rights. Beginning February 1, 2026, employers must provide a standalone written notice explaining certain workplace protections, including employee rights related to immigration enforcement, to all employees annually and to new hires at the time of hire.

The law also requires employers to allow employees to designate an emergency contact and—upon request—to notify that contact if the employee is arrested or detained in specified work-related circumstances.

Why this matters: Failure to provide required notices is a common (and easily avoidable) compliance issue that can support broader claims.

What employers should do:

• Distribute the Labor Commissioner’s updated model notice
• Update onboarding and personnel procedures

Expanded Access to Training & Education Records (SB 513) 

SB 513 expands employee access to personnel records by requiring employers who maintain education or training records to produce them upon request, along with detailed information about providers, duration, competencies, and certifications earned.

Why this matters: Training records are increasingly used in wage-and-hour, discrimination, and misclassification disputes.

What employers should do:

• Review how training records are stored and maintained
• Ensure records can be produced promptly and accurately

WARN Act Notice Updates (SB 617) 

California continues to enhance employee protections during mass layoffs and relocations. SB 617 expands the content required in WARN Act notices to ensure employees receive information about public benefits, workforce coordination, and how to contact the employer. Notices must now include information about coordination with local workforce development boards, CalFresh benefits, and a functioning employer email address and telephone number.

Why this matters: Deficient WARN notices can invalidate an otherwise compliant layoff process.

What employers should do:

• Update WARN templates before any workforce action

Restrictions on “Stay-Or-Pay” Agreements (AB 692) 

AB 692 reflects legislative concern that repayment obligations tied to termination can unlawfully restrict employee mobility. Effective January 1, 2026, most provisions requiring employees to repay training costs, sign-on bonuses, relocation payments, or other amounts because they resign or are terminated are void and unenforceable, unless they fall within a narrow statutory exception or are set forth in a separately negotiated agreement that complies with AB 692’s requirements.

Why this matters: Common arrangements—particularly training reimbursement, relocation repayment provisions, and executive compensation agreements— now carry enforceability risk if not properly structured.

What employers should do:

• Review training, bonus, relocation, and executive agreements for repayment or clawback provisions
• Replace, revise, or restructure noncompliant provisions, including through separate agreements

PAY EQUITY, TRANSPARENCY & DATA REPORTING 

Expanded Pay Transparency and Equal Pay Act Protections (SB 642) 

SB 642 builds on California’s aggressive pay equity framework by requiring employers to post good-faith pay ranges in job postings and by broadening the scope of the Equal Pay Act. The law also expands what counts as “wages” to include bonuses, equity, benefits, and other forms of compensation. In addition, the statute of limitations has been extended, allowing claims to reach back up to six years in certain circumstances.

Why this matters: Pay equity claims increasingly rely on total compensation—not just base salary—and documentation is critical.

What employers should do:

• Review job postings for compliant pay ranges
• Conduct holistic compensation audits across all pay elements

Expanded Pay Data Reporting Requirements (SB 464) 

California has strengthened enforcement of its pay data reporting regime by mandating penalties for noncompliance and requiring demographic data to be stored separately from personnel files. Beginning January 1, 2027, reporting categories will more than double.

Why this matters: Reporting errors now carry automatic penalties, and preparation time is shrinking.

What employers should do:

• Review HRIS and data storage practices now
• Begin planning for expanded 2027 reporting, which will first be due on May 10, 2028

EXPANDED LEAVE & WORKER PROTECTIONS 

Crime Victim & Court-Related Leave (AB 406) 

AB 406 reflects the Legislature’s continued expansion of protected leave rights. Employees may now take protected time off for a broader range of court proceedings, including those involving family members. Covered proceedings include hearings related to arrest, plea, sentencing, or post-conviction matters, and apply to a wide range of serious offenses, including violent felonies, DUI with injury, stalking, and similar crimes. The law also expands permissible uses of paid sick leave, allowing employees to use sick leave to appear in court as a witness under subpoena or court order, or to serve on a jury.

Why this matters: Leave laws are frequently implicated in retaliation and interference claims.

What employers should do:

• Update leave policies and handbooks
• Train managers on expanded protections

WAGE ENFORCEMENT & CLASSIFICATION RISK 

Enhanced Penalties for Unpaid Wage Judgments (SB 261) 

To deter nonpayment of wage judgments, SB 261 authorizes courts to impose civil penalties of up to three times the unpaid judgment amount, including post-judgment interest, and to award attorneys’ fees and costs if a final wage judgment remains unpaid more than 180 days after the appeal period expires, absent a showing of good cause.

Why this matters: Delayed payment can now exponentially increase liability.

What employers should do:

• Confirm all wage judgments are promptly satisfied

Strengthened Gratuity Enforcement (SB 648) 

SB 648 empowers the Labor Commissioner to independently investigate gratuity violations, signaling increased scrutiny of tip pooling and service-charge practices.

What employers should do:

• Audit gratuity and service-charge policies

Transportation, Trucking Amnesty & Reimbursement Rules (SB 809) 

SB 809 provides limited relief for construction trucking employers with potential past misclassification exposure, while also clarifying driver classification standards and reinforcing reimbursement obligations. The law creates an amnesty program allowing eligible construction trucking contractors to avoid penalties for prior misclassification if they enter into a settlement agreement with the Labor Commissioner by January 1, 2029, and agree to properly classify drivers going forward.

Separately, SB 809 clarifies that ownership of a vehicle alone does not establish independent contractor status and reinforces that Labor Code section 2802 requires reimbursement for the business use of personal or commercial vehicles, regardless of who owns the vehicle. These provisions apply broadly to construction and transportation employers and underscore continued scrutiny of driver classification and expense reimbursement practices.

What employers should do:

• Review driver classification and reimbursement policies
• Evaluate potential eligibility for the amnesty program and plan for compliant classification going forward

LABOR RELATIONS, AI & EMERGING ISSUES 

Several new laws expand state labor board authority, regulate emerging technologies, strengthen civil rights enforcement, and extend industry-specific worker protections. While some measures apply only to particular sectors, each reflects California’s continued shift toward broader regulatory oversight, expanded agency jurisdiction, and heightened enforcement risk.

Expanded Labor Relations & Collective Bargaining Authority 

AB 288 expands the jurisdiction of the California Public Employment Relations Board (PERB) to hear representation and unfair labor practice claims involving certain private sector workers if federal jurisdiction under the NLRA is repealed, limited, not enforced, or effectively ceded by the NLRB, including where a case has been pending before the NLRB for more than 12 months. The law also clarifies that the Agricultural Labor Relations Board is not required to follow NLRB precedent. AB 288 is currently the subject of a federal preemption challenge that may affect enforcement.

Separately, AB 1340 grants collective bargaining rights to Transportation Network Company (TNC) drivers, including the right to organize and engage in protected concerted activity, and assigns PERB authority over representation proceedings and new reporting requirements. Companies operating in or adjacent to the gig economy should assess whether their worker relationships fall within this framework.

Artificial Intelligence, Bias Training & Civil Rights Enforcement 

SB 53 imposes new governance and reporting obligations on developers of large “frontier” AI models operating in California. Covered entities must publish AI framework reports addressing safety and risk mitigation, report certain AI-related incidents, and maintain internal whistleblower reporting mechanisms. While not employment-specific, the law has implications for employers developing or heavily relying on advanced AI systems.

SB 303 supports the use of bias mitigation training by clarifying that an employee’s good-faith acknowledgment of bias during such training does not, by itself, constitute unlawful discrimination. The law is intended to encourage voluntary or mandatory bias training without increasing litigation risk.

SB 477 expands the California Civil Rights Department’s enforcement authority by clarifying group and class complaint procedures and extending tolling of the statute of limitations during CRD investigations, internal appeals, and written extensions. Once a right-to-sue notice issues, the complainant retains one year to file suit.

Hospitality & Contractor Compliance Updates 

AB 858 extends COVID-19 recall and reinstatement obligations through January 1, 2027 for certain hospitality, airport, event center, and commercial property service employers. Covered employers must continue offering qualified laid-off employees available positions in order of seniority.

SB 291 increases penalties for licensed contractors operating without workers’ compensation coverage, with maximum fines ranging from $10,000 to $30,000 depending on entity type and repeat violations. The law underscores the importance of maintaining continuous coverage and verifying compliance by subcontractors.

IN CLOSING 

California employment law continues to evolve rapidly, with enforcement agencies armed with greater authority and penalties. Employers who take a proactive, strategic approach—rather than a reactive one—are best positioned to manage risk.

This blog post is not offered, and should not be relied on, as legal advice. You should consult an attorney for advice in specific situations. 

KEY DEVELOPMENTS

• Major US, UK and EU designations: US designation of Clan del Golfo as an FTO and SDGT; EU asset-freeze measures linked to gang violence in Haiti; UK Russia-regime designations of the GRU and associated foreign information manipulation networks following the Dawn Sturgess Inquiry; UK cyber-sanctions designations of China-based technology companies; US and UK sanctions targeting Rapid Support Forces leadership; PRC sanctions against selected US defence companies and executives following approval of a Taiwan arms sale.

• Sanctions litigation and judicial developments: UK Commercial Court judgment in Beneathco DMCC v R.J. O’Brien Ltd dismissing an Iran-related payment claim and confirming application of the Ralli Bros principle; UK Commercial Court refusal in FH Holding Moscow Ltd v AO UniCredit (Russia) and UniCredit SpA to grant an anti-suit injunction in Russia-related foreclosure proceedings; PJSC VTB Bank v HM Treasury confirms OFSI’s statutory discretion to amend general licences under the UK Russia sanctions regime.

• Cyber-related sanctions expansions: UK designations under the Cyber (Sanctions) (EU Exit) Regulations 2020 targeting China-based entities alleged to have supported malicious cyber activity against UK public- and private-sector systems; UK Russia-regime sanctions targeting coordinated foreign information manipulation and interference involving fake news websites, social media accounts and automated bot networks.

• Significant Russia-related developments: EU Council renewal of sectoral sanctions against Russia through 31 July 2026 by Council Decision (CFSP) 2025/2648; OFAC imposition of an approximately US $7.1 million civil penalty against Gracetown, Inc. for dealings involving blocked property owned by Oleg Deripaska and related reporting failures; US Treasury extension of the deadline for permitted negotiations relating to PJSC Lukoil’s foreign assets; EU agreement on a €90 billion loan package for Ukraine.

• Geopolitical adjustments to sanctions regimes: US lifting of sanctions on Belarusian potash exports; US delisting of Brazilian Supreme Court Justice Alexandre de Moraes and related parties; UK delisting of Munir Al Qubaysi under the Iraq regime; UK de-listings and new designations under the Syria sanctions regime.

• Regulatory and licensing updates:  OFSI amendment to the Legal Services General Licence (INT/2025/7323088); amendments to Russian travel and oil-related General Licences; issuance of a Russian oil wind-down licence; introduction of a Myanmar humanitarian General Licence.

GLOBAL SANCTIONS

BELARUS

• On 13 December 2025, the United States lifted sanctions on Belarusian potash exports, a key source of revenue for Belarus and a critical input in global fertiliser supply chains. The decision followed the release by Belarusian authorities of 123 detainees, including political prisoners and individuals associated with opposition activity against the government of President Alexander Lukashenko.

BRAZIL

• On 12 December 2025, the United States removed Brazilian Supreme Court Justice Alexandre de Moraes, his wife, and the Lex Institute from its Specially Designated Nationals (SDN) List, reversing sanctions imposed earlier in the year under the Global Magnitsky Human Rights Accountability Act. The original designation had frozen any US-based property and prohibited dealings with US persons and was linked to Moraes’s role in overseeing criminal proceedings against former President Jair Bolsonaro. The delisting followed diplomatic engagement between US and Brazilian officials.

CHINA

• On 4 and 9 December 2025, the UK Government designated Integrity Technology Group Incorporated and Sichuan Anxun Information Technology Co., Ltd. under the Cyber (Sanctions) (EU Exit) Regulations 2020. The entities are alleged to have supported malicious cyber activity affecting UK public-sector and private-sector IT systems, including through botnet operations and the provision of cyber-intrusion services. The designations impose asset freeze measures and prohibit UK persons from making funds or economic resources available to the listed entities.

COLOMBIA

• On 16 December 2025, the US Department of State designated the Colombia-based Clan del Golfo as both a Foreign Terrorist Organization (FTO) and a Specially Designated Global Terrorist (SDGT) entity under US law. According to the State Department, Clan del Golfo is responsible for widespread violence, drug trafficking, extortion and other criminal activity that undermines civilian security and regional stability. The designation blocks Clan del Golfo’s property and interests in the United States and generally prohibits US persons from engaging in transactions with the group or its members.

HAITI

• On 15 December 2025, the EU adopted new asset-freeze measures against three individuals and one entity connected to serious human rights abuses and gang-related violence in Haiti. The designations target persons assessed to be responsible for, or complicit in, activities contributing to widespread insecurity, including violence carried out by organised criminal groups.

IRAN

• On 24 November 2025, the UK Commercial Court delivered its judgment in Beneathco DMCC v R.J. O’Brien Ltd. The case concerned a UAE-based entity that held approximately USD 16.5 million in a derivatives trading account with an FCA-regulated broker at the time it was designated under the US Iran sanctions regime. The claimant later sought to recover the funds by issuing amended payment instructions directing payment to an account held by a third party. The Court dismissed the claim, concluding that no valid payment demand had been made because the contractual terms required payment in US dollars, and the request for payment in a different currency was ineffective. The Court further held that the broker was entitled to rely on the Ralli Bros principle, as making payment in US dollars would have involved an act within the US and would have resulted in a breach of US sanctions.

• On 30 December 2025, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated 10 individuals and entities in Iran and Venezuela for their roles in the Iran-Venezuela weapons trade, including a Venezuelan company and its chairman that acquired Iranian-designed unmanned aerial vehicles (UAVs) and assisted in their sale and assembly in Venezuela. The action, taken under Executive Orders targeting weapons proliferation, also included Iran-based persons involved in procuring chemicals used in ballistic missile programs and thereby supporting Iran’s UAV and missile development. According to OFAC, the designations build on previous nonproliferation measures and U.N. sanctions reimposed in September 2025 and reflect US efforts to disrupt the flow of Iranian conventional weapons to Caracas, which are assessed to threaten US and allied personnel and destabilize regional security.

IRAQ

• On 10 December 2025, the UK Government removed Munir Al Qubaysi from the UK’s Iraq sanctions regime, following his delisting from the UN sanctions list. Mr Al Qubaysi had originally been designated in 2004 in connection with his role as director of Al-Bashair Trading Company, which was reported to have operated as a major front company involved in Iraq’s arms procurement activities.

RUSSIA

• On 24 November 2025, the UK court declined to grant anti-suit injunction in Russia-related proceedings. The UK Commercial Court has refused an application for an anti-suit injunction in FH Holding Moscow Ltd v AO UniCredit (Russia) and UniCredit SpA. The dispute arose out of a financing arrangement entered into in 2018 under which a Russian operating company borrowed funds from an Italian bank pursuant to an English law–governed facility agreement providing for arbitration in Vienna. Separate security arrangements over Russian property were governed by Russian law and subject to the jurisdiction of the Russian courts. Following the commencement of foreclosure proceedings in Moscow in March 2025, the borrower sought to restrain those proceedings on the basis that the Russian courts might require conduct that would place it in breach of EU Russia sanctions. The Court rejected the application, finding that the risk of any sanctions breach was speculative and insufficiently concrete to justify intervention. It also held that the UK’s public policy interest in supporting EU sanctions, without additional factors connecting the dispute to the English courts, did not provide a sufficient basis for granting anti-suit relief.

• On 4 December 2025, the UK Government designated multiple individuals and entities under the Russia and Cyber sanctions regimes, including Russia’s military intelligence agency (the GRU) and associated officers. The designations followed the publication of the final report of the Dawn Sturgess Inquiry into the Salisbury poisonings, which concluded that GRU agents were responsible for the attack. The measures target those involved in cyber-attacks, disinformation, sabotage and political interference undermining UK security.

• On 4 December 2025, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed an approximately $7.1M civil penalty on New York–based property management company Gracetown, Inc. for violations of the Ukraine-/Russia-Related Sanctions Regulations and related reporting obligations. OFAC found that, between April 2018 and May 2020, Gracetown knowingly received 24 payments on behalf of a British Virgin Islands–based entity ultimately owned by designated Russian oligarch Oleg Deripaska, despite having received explicit notice from OFAC that all dealings involving Deripaska and his property were prohibited. OFAC further determined that Gracetown failed to timely report blocked property for more than 45 months, including an accumulated debt owed to a Deripaska-owned entity, and classified the conduct as egregious and not voluntarily self-disclosed, underscoring enforcement risks for US service providers that continue dealings or fail to meet blocking and reporting requirements following designation.

• On 9 December 2025, the UK Government designated seven individuals and entities under the Russia sanctions regime in connection with foreign information manipulation and interference (FIMI) activities. Those designated include Rybar LLC and its director Mikhail Zvinchuk, the Centre for Geopolitical Expertise and its founder Aleksandr Dugin, and several organisations linked to PRAVFOND, a Russian state-backed body. The designated parties are alleged to have been involved in coordinated efforts to undermine democratic processes through the creation of fake news websites and the use of social media and automated bot accounts to disseminate misleading narratives supportive of Russia’s war in Ukraine.

• On 12 December 2025, the US Treasury extended the deadline for permitted negotiations relating to Lukoil’s foreign assets to 17 January 2026, postponing the previous cut-off of 13 December 2025. According to Reuters, Saudi Arabia’s Midad Energy has emerged as a leading contender in the potential acquisition process and has proposed a transaction structure involving an upfront cash payment alongside escrow arrangements, under which sale proceeds would be held in a designated escrow account pending the lifting of sanctions on Lukoil.

• On 16 December 2025, the EU Council renewed its sectoral sanctions against Russia for a further six months, until 31 July 2026, by adopting Council Decision (CFSP) 2025/2648. The sectoral measures include restrictions on Russia’s financial, energy, defence and dual-use goods sectors, and form part of one of the EU’s six Russia-related sanctions regimes. The renewal maintains the existing framework of economic restrictions introduced in response to Russia’s actions undermining Ukraine’s territorial integrity and reflects the EU’s continued policy of sustained sanctions pressure.

• On 19 December 2025, the Administrative Court rejected a claim brought by PJSC VTB Bank (VTB) challenging a decision of OFSI to amend a general licence. In PJSC VTB Bank v HM Treasury, VTB argued that OFSI’s amendment of the licence was unlawful. The Court dismissed the claim, confirming that OFSI was entitled to amend the general licence in the exercise of its statutory powers. The judgment underscores the broad discretion afforded to HM Treasury and OFSI in the administration and modification of sanctions licensing arrangements under the UK’s Russia sanctions framework.

SUDAN

• On 9 December 2025, the US Department of the Treasury’s OFAC imposed sanctions on four individuals and four entities linked to a transnational network that recruited and trained former Colombian military personnel to fight for the Sudanese paramilitary group known as the Rapid Support Forces (RSF). OFAC stated that the network provided training and support, including to child soldiers, in furtherance of RSF operations contributing to Sudan’s ongoing conflict. Subsequently, on 12 December 2025, the UK sanctioned four senior RSF commanders, including RSF Deputy Leader Abdul Rahim Hamdan Dagalo, for their alleged responsibility for mass killings, sexual violence and attacks on civilians, imposing asset freezes and travel bans. The UK simultaneously announced an additional £21 million in humanitarian assistance, underscoring a parallel strategy of targeted sanctions and humanitarian support in response to the crisis.

• On 27 December 2025, President Volodymyr Zelenskyy signed two decrees enacting decisions of Ukraine’s National Security and Defence Council to align parts of Ukraine’s sanctions regime with those of the UK and to implement restrictions consistent with United Nations Security Council resolutions. Under the first decree, Ukraine imposed sanctions on eight individuals and 40 legal entities, including persons and companies linked to forced child deportations, supply of dual-use electronics and components used in Russian missile and drone production, and entities facilitating circumvention of sanctions and energy-sector support. The second decree implements sanctions in line with UN Security Council mandates concerning South Sudan, targeting eight members of the country’s military leadership for their role in prolonging conflict and committing serious abuses. These coordinated actions form part of Ukraine’s broader effort to align its sanctions measures with key international partners.

SYRIA

• On 19 December 2025, the UK added nine new designations, consisting of 6 individuals and 3 entities, all subject to an asset freeze. This followed four de-listings under the Syria regime on 17 December 2025. All de-listings remain subject to sanctions in other jurisdictions, namely the Iran regime, the Iran (Nuclear) regime, and the Chemical Weapons regime.

TAIWAN

• On 26 December 2025, China’s Ministry of Foreign Affairs announced sanctions on 20 US defence-related companies and 10 senior executives following Washington’s approval of a roughly US $11.1 billion arms sale to Taiwan, one of the largest packages in recent history. The sanctions freeze any assets the targeted firms and individuals hold within China and bar Chinese entities and citizens from entering into business with them. The list includes major defence contractors such as Northrop Grumman Systems Corporation, L3Harris Maritime Services and Boeing’s St. Louis defence unit, as well as executives including the founder of Anduril Industries. China’s foreign ministry described the measures as a necessary response to what it called provocations that “cross the line” on the Taiwan issue, reiterating that Taiwan is a core national interest and rejecting external arms transfers to the island.

UKRAINE

• On 19 December 2025, EU leaders agreed to provide Ukraine with a €90 billion loan package intended to cover Kyiv’s budgetary and defence needs over the next two years. The loan will be financed through joint EU borrowing backed by the EU budget, rather than by using Russian sovereign assets frozen in the EU, despite earlier proposals to do so. Member States failed to reach consensus on making immobilised Russian assets part of the financing mechanism, primarily due to legal and financial risk concerns. Ukrainian President Volodymyr Zelenskyy welcomed the agreement, noting its significance for Ukraine’s resilience, and emphasised that Russian assets will remain immobilised.

VENEZUELA

• On 11 December 2025, the US Treasury’s Office of Foreign Assets Control (OFAC) imposed sanctions on a group of individuals and entities connected to the Maduro government in Venezuela, including three members of President Nicolás Maduro’s family, a Panamanian businessman, six shipping companies and a number of vessels. OFAC stated that two of the family members were designated under US counter-narcotics authorities, on the basis of alleged involvement in drug trafficking activities in Venezuela. The remaining family member, together with the Panamanian businessman, the shipping companies and the vessels, were designated for their alleged role in facilitating the illicit transport of Venezuelan oil, including activities linked to the Government of Venezuela and state-owned entities such as Petróleos de Venezuela, S.A. (PdVSA).

• On 31 December 2025, OFAC imposed sanctions on four Venezuelan oil-sector companies and identified four associated oil tankers—Nord Star, Rosalind (also known as Lunar Tide), Della, and Valiant—as blocked property for operating in Venezuela’s oil economy and facilitating revenue flows to the Maduro government. OFAC noted that these actions form part of an intensifying campaign against Venezuela’s illicit oil trade and its “shadow fleet” of vessels used to evade sanctions and generate funds for regime activities. The designations block any US property or interests of the companies and tankers and prohibit US persons from engaging in transactions with them.

GLOBAL REGULATIONS/TOOLS UPDATE: OFSI

General Licenses 

Legal Services General Licence (INT/2025/7323088), amended 17 December 2025

OFSI’s Legal Services General Licence INT/2025/7323088 took effect on 29 October 2025, replacing the previous legal services licence and permitting UK law firms, counsel and related service providers to receive payment for legal services provided to designated persons under most UK autonomous sanctions regimes, subject to specified conditions. On 17 December 2025, the licence was amended to clarify that the definition of “legal services” expressly includes legal advice and representation in dispute resolution proceedings, correcting an omission in the original October version. The licence continues to impose financial caps, detailed reporting obligations within 14 days of payment, and six-year record-keeping requirements, and does not permit payments involving persons designated solely to comply with UN obligations.

Russia

Russian Travel General Licence (INT/2022/1839676), amended 12 December 2025

This licence permits UK persons to purchase passenger rail and air travel tickets from specified Russian transport providers, including Aeroflot, Russian Railways and their subsidiaries, for journeys originating in or within Russia, as well as certain rail routes between Armenia and Georgia. It also authorises UK financial institutions and intermediaries to process payments necessary to effect such ticket purchases. The licence remains subject to strict conditions and does not permit funds to be made available beyond what is expressly authorised, and is currently valid until 22 May 2028.

Russian Oil Exempt Projects General Licence (INT/2025/5635700), amended 17 December 2025
This licence permits continued business operations involving specified Russian oil companies and their subsidiaries, including PJSC Lukoil, Rosneft and Gazpromneft-Sakhalin, where activities relate solely to listed “Exempt Projects” such as Sakhalin-2, the Caspian Pipeline Consortium, TengizChevroil, Shah Deniz and Zohr. It authorises payments, contractual performance and certain shareholder activities connected to these projects for defined periods, subject to project-specific expiry dates set out in Schedule 1. The licence reflects the UK’s approach of preserving critical international energy projects while maintaining broader Russia sanctions restrictions, and includes six-year record-keeping obligations for all parties relying on its permissions

Russian Oil Companies Wind-Down General Licence (INT/2025/8202932), effective 18 December 2025

This licence authorises non-designated persons and relevant UK institutions to wind down transactions involving specified Russian oil companies, including PJSC Russneft and PJSC Tatneft, and their subsidiaries. Permitted activity includes closing out positions and taking steps reasonably necessary to effect an orderly wind-down. The licence is time-limited, expiring on 31 January 2026, and imposes record-keeping obligations requiring parties to retain transaction records for at least six years

Myanmar

Myanmar Humanitarian Activity General Licence (INT/2025/8257372), effective 19 December 2025

This General Licence permits specified humanitarian actors to carry out activities necessary to provide humanitarian assistance and support basic human needs in Myanmar, notwithstanding otherwise applicable prohibitions under the Myanmar and Global Human Rights sanctions regimes. The licence applies to UN bodies, UK-funded organisations, participating NGOs, international organisations and their partners, and allows the provision and processing of funds, goods and services required for humanitarian operations. Funds used must not be owned or controlled by a designated person, and any relevant organisation relying on the licence must notify HM Treasury within 30 days of commencing activities in Myanmar. The licence reflects the UK’s continued use of broad humanitarian carve-outs to facilitate aid delivery while maintaining sanctions pressure on designated actors.

CONCLUSION

December’s developments highlight the continued influence of US and UK sanctions authorities in shaping the global sanctions landscape through new designations, enforcement action, judicial clarification and targeted licensing updates. Alongside EU measures and selective sanctions relief linked to diplomatic and humanitarian objectives, these actions reflect an increasingly complex and enforcement-driven compliance environment for businesses and financial institutions operating across jurisdictions. MR’s monthly sanctions update will continue to monitor these developments, providing timely insight into international sanctions measures, regulatory reforms and key enforcement trends shaping the global sanctions landscape.

This blog post is not offered, and should not be relied on, as legal advice. You should consult an attorney for advice in specific situations.