Archive:July 2025

By: Michael E. Ruck, Rosie Naylor, Petr Bartoš, and Laura Scott

On 14 July 2025, the United Kingdom’s Foreign, Commonwealth and Development Office released important sanctions guidance aimed specifically at non-UK companies operating outside the United Kingdom, with a special focus on Russia-related sanctions (the Guidance). The Guidance also includes tailored advice for businesses active in Kazakhstan, Uzbekistan, Kyrgyzstan, Georgia and Armenia, countries that are frequently used as transit points to circumvent Russian sanctions.

By: Michael E. Ruck, Rosie Naylor, Petr Bartoš, and Laura Scott

On 18 June 2025, the UK Office for Financial Sanctions Implementation (OFSI) released a Threat Assessment (the Assessment) targeting Art Market Participants (AMPs) and High-Value Dealers (HVDs). This follows new rules from 14 May 2025, which make AMPs and HVDs legally responsible for reporting sanctions breaches involving designated persons (DPs).