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.
No items found.
No items found.
Date published
Get in touch
%20%C3%94%C3%87%C3%B4%20790px%20X%20451px%2072ppi2.jpg)
Get in touch
No items found.
Insights & events
FCA formalises annual retail banking data reporting: what banks and building societies need to do now
The countdown begins: what cryptoasset firms must do now to secure FCA authorisation
UK Regulatory Initiatives Grid – May 2026: what financial services firms need to know now
HMT’s policy statement on Consumer Credit Act 1974 reform: Insights for a future-ready consumer credit regime
New operational incident reporting rules for banks and CRR firms: What you need to do before March 2027
New FCA operational incident reporting rules: What core or limited SMCR firms need to do now
New FCA rules on operational incident reporting: What enhanced SMCR firms need to know
New operational incident reporting rules for payment service providers: What you need to do before March 2027
Consumer Duty: from frameworks to outcomes – 12 priority focus areas for regulated firms
FCA consults on overhaul of consumer credit financial promotion rules
SFO secures £10m DPA – what this means for corporates
Crime and Policing Act 2026: Expansion of senior manager criminal liability
FCA Synthetic Data and Anti-Money Laundering project report: Key points for financial services firms
SM&CR reform: HM Treasury announces Senior Managers and Certification Regime reforms
FCA's findings on Customer Due Diligence processes and controls: Good and poor practices
sort
tlt-continues-growth-of-financial-services-regulatory-team-with-appointment-of-new-partner
TLT continues growth of financial services regulatory team with appointment of new partner
No items found.
No items found.
No items found.
No items found.
Related services
Financial Services Regulatory
Economic crime