United Kingdom – National Security and International Trade Update

Key Takeaways: Secondary Sanctions—United Kingdom Issues Sanctions Guidance for Non-UK Businesses

Jul 21 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.

Key Lessons: The Latest UK Office for Financial Sanctions Implementation Art Market Participants and High Value Dealers Threat Assessment

Jul 18 2025

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).

UK Office of Trade Sanctions Implementation New Enforcement Powers and Increased Reporting Obligations

Nov 18 2024

By: Michael Ruck, Petr Bartoš, Rosie Naylor, and Helen Phizackerley

The new Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 (the Regulations), came into force on 10 October 2024.

Under the Regulations, the Office of Trade Sanctions Implementation (OTSI) will have new powers to investigate alleged breaches of trade sanctions and to take enforcement action in relation to:

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