On 10 February 2025, President Trump signed Executive Order 14209, directing the US Department of Justice (DOJ) to pause enforcement of the Foreign Corrupt Practices Act (FCPA) for 180 days. The stated rationale was that the FCPA had been ‘stretched beyond proper bounds’ in ways that harmed American economic competitiveness. Within weeks, on 20 March 2025, the UK’s Serious Fraud Office (SFO), France’s Parquet National Financier (PNF) and the Office of the Attorney General of

On 9 February 2026, the Office of Financial Sanctions Implementation (OFSI) published revised Enforcement and Monetary Penalties guidance. The reforms introduced a structured case assessment matrix, a settlement scheme, an Early Account Scheme for cooperative subjects and fixed penalties for reporting and licensing offences. OFSI has signalled its intention to seek legislation doubling the maximum civil penalty to the greater of £2 million or 100 per cent of the value of the

On 19 May 2026, the Department for Business and Trade (DBT) issued two new general trade licences under the Russia (Sanctions) (EU Exit) Regulations 2019 (the Russia Regulations), both of which came into force on 20 May 2026. The licences sit alongside the latest amendments to the regime, which introduced new prohibitions on the import of processed oil products derived from Russian crude and on the maritime transportation of Russian liquefied natural gas (LNG) — measures that

The Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, has imposed a £165,000 monetary penalty on Deutsche Bank AG London Branch (DBLB) for breaches of the Russia (Sanctions) (EU Exit) Regulations 2019. The penalty, announced on 30 April 2026, relates to two payments totalling £635,618.75 processed in June and July 2022 to Okko LLC (Okko), a Russian media streaming company wholly owned by the designated person JSC New Opportunities. DBLB processed the p

The UK government has brought into force the Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026, introducing a series of technical but operationally significant updates for firms subject to UK sanctions compliance obligations. The changes affect reporting thresholds, licensing procedures and the interpretation of existing sanctions exceptions. Firms operating in regulated sectors, particularly those with anti-money laundering and sanctions reporting obligations,

FinCEN’s 11 May 2026 Alert signals a renewed enforcement focus on Iran-linked illicit finance, with particular attention on the Islamic Revolutionary Guard Corps (IRGC), its oil smuggling networks and the financial infrastructure used to move proceeds through the international system. The Alert is significant because it connects several core risk areas: shadow fleet activity, front company abuse, exchange house networks, money services businesses, trust and company service pr

When the United Nations Security Council first imposed comprehensive sanctions against North Korea in 2006, the expectation was straightforward. Financial isolation would constrain a rogue state’s capacity to fund weapons proliferation. Two decades on, the US Treasury, the European Union and the UK have built an extensive sanctions architecture spanning asset freezes, trade restrictions, sectoral prohibitions and secondary designation powers. Yet the very sophistication of th

The Department for Business and Trade has introduced new Sanctions End-Use Controls (SEUC), marking a significant escalation in the UK’s efforts to prevent the circumvention of trade sanctions. Published on 22 April 2026, the guidance clarifies how exporters must respond where there is a credible risk that goods routed through third countries could ultimately reach sanctioned jurisdictions or individuals. At its core, SEUC creates a targeted licensing mechanism. Unlike tradit

The forthcoming Sanctions EU Exit Miscellaneous Amendments Regulations 2026 introduce a series of targeted but operationally significant changes to the UK sanctions framework. While largely technical in nature, the reforms are clearly designed to streamline compliance obligations, remove inconsistencies and enhance the flexibility of the Office of Financial Sanctions Implementation OFSI. A notable change is the shift from euro denominated thresholds to pound sterling across r

The Office of Financial Sanctions Implementation (OFSI) has published its Strategy for 2026 to 2029, signalling a decisive shift towards intelligence led enforcement, faster licensing and deeper international coordination. The strategy reflects a more complex geopolitical and financial crime landscape, where sanctions are increasingly central to national security and economic resilience. At its core is the Promote, Enable, Respond and Change (PERC) framework, designed to resh

The Office of Trade Sanctions Implementation (OTSI) has announced a significant expansion of its licensing remit, marking a structural shift in the UK’s export sanctions framework. From 27 April 2026, OTSI will assume responsibility for licensing sanctioned goods and associated ancillary services exported to sanctioned destinations, building on its existing role overseeing standalone services such as professional and business services. This change clarifies the division of re

In February 2022, the US, the UK and the European Union imposed the most comprehensive sanctions regime in modern history on the Russian Federation. The ambition was sweeping: sever the financial arteries funding military aggression, freeze the assets of those who enabled it and impose a cost so severe that the war economy could not sustain itself. Hundreds of individuals were designated. Russian banks were cut from SWIFT. Sectoral restrictions targeted energy, technology and