This first 2026 edition considers evolving UK sanctions enforcement practice, government policy responses to sanctions evasion, and Parliamentary scrutiny of the UK’s Magnitsky-style regimes.
It considers, amongst other matters, OFSI’s imposition of a monetary penalty on the Bank of Scotland, the purported use of UK statutory powers to board and detain ‘shadow fleet’ vessels, and the parliamentary debate questioning the effectiveness of the UK’s ‘Magnitsky’ sanctions.
Key updates include:
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Crypto-Assets and Sanctions Evasion: OFSI’s announcement that it has joined the Crypto Cash Fusion Cell, a multi-agency initiative targeting the abuse of crypto-assets and associated money laundering linked to sanctions offences.
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Sanctions Enforcement Reform: OFSI’s consultation response on proposed reforms to enforcement processes, including increased maximum penalties, new settlement and early account schemes, revised voluntary disclosure discounts, streamlined treatment of reporting and licensing offences, and a more dialogue-led approach to investigations.
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Shadow Fleet Vessels: UK Government statements asserting legal authority under SAMLA to board and detain sanctioned ‘shadow fleet’ tankers used to evade oil sanctions, amid growing concern over large-scale sanctions circumvention.
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UK Sanctions List Reform: The move to a single UK Sanctions List (UKSL) from 28 January 2026, replacing OFSI’s Consolidated List, alongside enhanced search functionality and the publication of FCDO designation notices.
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Magnitsky Sanctions Debate: Parliamentary debate questioning the effectiveness of the UK’s Magnitsky-style sanctions regimes, highlighting concerns around inconsistent application, enforcement gaps, asset management and the need for stronger oversight.
Read the full update by clicking on the image below:
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