Sanctions Watch | Weekly Vol. 100

Sanctions Watch Vol 100

In the latest edition of our Sanctions Watch weekly digest, we present significant updates on sanction watchlists and regulatory developments.

1. UK Solicitors Regulation Authority Enhances Sanctions Compliance Guidance Amid Evolving Legal Landscape

The UK Solicitors Regulation Authority (SRA) has released significant updates to its guidance on sanctions compliance, originally issued in November 2022. Reflecting ongoing legal developments and insights gathered from enforcement practices post-Russia’s invasion of Ukraine, the revised guidance aims to strengthen law firms’ understanding and adherence to the UK sanctions regime. Noteworthy enhancements include a new case study highlighting how firms may inadvertently breach sanctions regulations, and an expanded list of red flags concerning circumvention attempts. New requirements have been added for staff screening during onboarding and clearer responsibilities for self-reporting.

The guidance also clarifies when firms must report issues directly to the SRA, beyond the usual enforcement bodies. A crucial clarification differentiates beneficial ownership thresholds: 25% under anti-money laundering rules versus a 50% threshold commonly applied in sanctions contexts. The SRA underscores that breaches can result in criminal penalties, including fines and imprisonment.

Best practices from recent inspections are featured, such as the establishment of specialized sanctions committees comprising legal, compliance, and finance professionals. The updated document also includes refreshed external links to ensure firms access current resources. The SRA reiterates the complexity of the regime and advises firms to only provide relevant services when properly equipped with the necessary expertise.

2. UK Unleashes Record Sanctions on Russia’s Shadow Fleet to Safeguard National Infrastructure

The Prime Minister announced the UK’s largest sanctions package targeting Russia’s shadow fleet during the Joint Expeditionary Force (JEF) summit in Oslo. This move underscores the UK’s escalating response to safeguard critical national and subsea infrastructure and cut off funding for Russia’s war efforts in Ukraine. The sanctions will affect up to 100 oil tankers involved in transporting over $24 billion worth of Russian oil in 2024, vessels described as “decrepit and dangerous.” These tankers not only support the Kremlin’s illegal war machine but also threaten essential infrastructure through unsafe maritime practices.

The UK government emphasized that the shadow fleet’s operations jeopardize 99% of international telecommunications and vital energy links. The Nordic Warden surveillance system, activated earlier in 2025, monitors potential threats across 22 European maritime zones, including the English Channel and Baltic Sea. In parallel, a new JEF-Ukraine partnership will focus on military training, disinformation countermeasures, and strategic collaboration.

Furthermore, the UK and Norway are set to sign a space domain awareness agreement to enhance monitoring of space assets and debris, complementing the UK’s growing presence in the space sector. These initiatives reaffirm the UK’s commitment to European security, economic resilience, and long-term deterrence against Russian aggression.

3. EU Extends Sanctions Against Malicious Cyber-Attacks to 2026, Reinforces Legal Framework Until 2028

The European Council announced an extension of the EU’s restrictive measures targeting malicious cyber-attacks that threaten the security of the EU and its member states. These sanctions, originally set up in May 2019, will now remain in effect until 18 May 2026, while the overarching legal framework governing such actions has been extended until 18 May 2028. This regime empowers the EU to impose asset freezes, travel bans, and restrictions on providing funds or resources to individuals or entities involved in cyber operations with significant harmful impacts.

Currently, 17 individuals and four entities face these sanctions. The measures not only address threats to the EU directly but also cover cyber-attacks on third countries or international organizations when necessary to achieve the EU’s Common Foreign and Security Policy (CFSP) objectives. The listings are reviewed annually to ensure ongoing relevance.

This decision reflects the EU’s ongoing commitment to safeguarding its digital infrastructure and maintaining an open, secure, and rules-based cyberspace. It also reinforces the cyber diplomacy toolbox established in 2017 and revised in 2023, enabling a more strategic and coordinated approach to persistent cyber threats. The EU pledges continued cooperation with international partners to promote global cyber stability.

4. OFSI Renewed Amsterdam Trade Bank General License Until 2030 to Support Basic Operations and Insolvency Proceedings

The UK’s Office of Financial Sanctions Implementation (OFSI) officially renewed General License INT/2022/1678476, extending its expiry from 12 May 2025 to 12 May 2030. Originally issued on 12 May 2022, the license pertains to Amsterdam Trade Bank N.V. (ATB), a majority-owned subsidiary of Alfa-Bank JSC, a designated Russian entity under UK sanctions. The license aims to ensure that necessary financial and legal processes tied to ATB can proceed without breaching sanctions imposed under The Russia (Sanctions) (EU Exit) Regulations 2019.

The license authorizes ATB to carry out payments related to basic operational needs such as employee salaries, taxes, and supplier obligations. It also allows any party, including insolvency practitioners and the court-appointed bankruptcy trustees, to manage and process payments and legal duties connected to ATB’s insolvency. Furthermore, it permits third parties to wind down any existing transactions with ATB or its subsidiaries, including closing positions and restructuring debt. The license requires notification to HM Treasury for any such activity and mandates strict recordkeeping for at least six years. This move by OFSI supports financial stability and legal clarity while maintaining the integrity of the UK’s sanctions regime against Russia.

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Sanctions Watch is a weekly recap of events and news related to sanctions around the world.