Cross-Government Sanctions Enforcement Review

TLT picks out the points you shouldn't miss...

What’s this about?

In May 2025, the UK government published its latest review on sanctions implementation and enforcement, outlining critical updates for businesses navigating compliance obligations.

Our Head of Risk and Compliance Advisory, Ben Cooper says...

“The key message from this review is that sanctions compliance is now a board-level issue for businesses across all sectors. With enforcement powers expanding and guidance evolving, proactive risk assessments and robust controls are no longer optional — they are essential. Businesses need to stay agile and informed to protect themselves and ensure they are meeting their obligations in a rapidly changing landscape.”

Strengthened enforcement

Record penalties: Recent enforcement actions include a £465,000 OFSI fine for financial sanctions breaches and HMRC’s £1.36m in settlements against Russia trade violations.
New agencies: The Office of Trade Sanctions Implementation (OTSI) now oversees civil enforcement of trade sanctions, complementing OFSI’s financial sanctions role.
Criminal convictions: The NCA secured the first convictions for breaches of Russia sanctions in April 2025.

Compliance simplification

Single sanctions list: The UK Sanctions List and HM Treasury’s Consolidated List will merge to streamline screening.
Enhanced guidance: Updated GOV.UK resources and sector-specific outreach aim to support SMEs and less familiar industries.
Ownership clarity: New measures to address complex due diligence challenges for entities with sanctioned ownership ties.

Deterrence strategies

Public enforcement reporting: Regular updates on penalties and “teachable moments” to drive compliance.
Whistleblower protections: Expanded safeguards for reporting breaches of financial, trade, and transport sanctions.
Faster penalties: Proposals for accelerated civil settlements and fixed penalties for minor breaches.

What this means for businesses

Proactive compliance reviews are essential, particularly for sectors newly exposed to sanctions risks (e.g., manufacturing, tech).
Monitor updates: Subscribe to the new UK sanctions alert service for real-time regulatory changes.
Prepare for stricter scrutiny: Cross-government intelligence sharing and expanded enforcement tools signal a tougher stance on evasion.

At TLT, we’re helping clients navigate these evolving requirements with tailored compliance frameworks and risk assessments.

At a glance...

Publication link:	Cross-government review of sanctions implementation and enforcement - GOV.UK
Published date:	15 May 2025
Who has published it?	FCDO
Publication type:	Review report
What's it relevant to?	Sanctions compliance UK regulation Financial crime

This publication is intended for general guidance and represents our understanding of the relevant law and practice as at June 2025. Specific advice should be sought for specific cases. For more information see our terms and conditions.

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Date published

20 Jun 2025