UK Sanctions Regulator Highlights Compliance Failures

Western countries are increasingly focussed on the effective implementation of their sanctions regimes.

Partner John Binns and Principal Associate Alex Gorst examine significant developments in UK and international sanctions law, including new sectoral measures against Iran, proposed Israeli settlement sanctions, OFSI's £4.7 million Citibank penalty, and the US Treasury's intensified Operation Economic Outcast targeting Iranian networks.

Recent enforcement actions by the UK's FCA and OFSI emphasize the need for businesses to implement effective financial crime and sanctions controls. Starling Bank was fined £28.9M for control failures, while ICSL faced penalties for sanctions breaches.

The UK Government has codified the annual "Frozen Assets Review" under its sanctions regimes, through the Sanctions (EU Exit) (Miscellaneous Amendments) (No 2) Regulations 2024 ("Amending Regulations").

It is a pernicious feature of sanctions laws that they affect far more people than they target.

The Solicitors Regulation Authority for England and Wales has, in its Annual Report for Money Laundering covering 2023/2024, has stated that it has required 9 law firms to report themselves...

In this post we bring you a round-up of recent developments relating to the enforcement of UK trade sanctions breaches, together with news of further Russia-related designations

Welcome to BCL’s latest sanctions and export controls round-up, highlighting the key developments in UK and international sanctions

In this post, we summarise recent developments regarding the UK sanctions imposed on Russia. On 19 May, the UK announced the addition of 86 further entries to its asset freeze list.

The UK’s National Crime Agency has published a press release confirming that it has charged John Michael Ormerod with two counts of breaches the UK’s Russian sanctions as well...

On 30 September 2026, the SEC proposed rule amendments advancing Chairman Paul S. Atkins’ “responsible retailization” of private markets, expanding retail access to private-market strategies while adding key investor safeguards.

The Federal Trade Commission has issued a proposed enforcement policy statement targeting businesses that use consumer personal data to set individualized prices. While acknowledging it cannot prohibit all personalized pricing, the FTC warns that companies may violate federal law if they fail to clearly disclose their use of personal data in pricing decisions.

Texas Senate Bill 140 (SB 140) took effect 1 September 2025, and applies to conduct occurring on or after that date. The bill amended Section 302 of the Texas Business and Commerce Code to extend registration and disclosure requirements to text messages by expanding the definition of “Telephone solicitation,” which previously applied only to a “telephone call,” to include certain transmissions of text or graphic messages and images. In addition, SB 140 added a definition of “Telephone call” that incorporates the definition found in Section 304, which includes certain text or graphic messages and images, but excludes certain agreed-to transmissions.

The SEC and CFTC have issued coordinated regulatory relief measures that significantly advance crypto-based trading infrastructure in US markets, bypassing Congressional gridlock on the CLARITY Act. These orders establish new frameworks for tokenized securities venues and passive software providers, potentially reshaping how digital assets are traded and accessed in regulated markets.

The European Commission has issued guidelines on transparency obligations under Article 50 of the EU AI Act, clarifying how providers and deployers must inform individuals when they interact with AI systems or are exposed to AI-generated content. These non-binding guidelines address a wide range of AI applications, from chatbots to deepfake technologies, and establish four main transparency scenarios with specific disclosure requirements that businesses must now prepare to implement.

Venezuela's post-Maduro reopening is creating unprecedented opportunities for foreign investors across energy, mining, telecommunications, and infrastructure sectors. With expanding OFAC sanctions relief, landmark legislative reforms, and major US companies nearing multibillion-dollar deals, the country presents investment prospects not seen in a generation—though success requires disciplined navigation of corruption, security, and regulatory risks.

The EU has introduced its first major amendment to the AI Act through the AI Omnibus regulation, which delays certain compliance deadlines while maintaining others. Organizations must understand which obligations remain on schedule, including transparency requirements and general-purpose AI provisions, and which have been deferred, such as high-risk AI system requirements.

The European Union's new Consumer Rights Directive amendment introduces a mandatory "withdrawal button" for online merchants, fundamentally changing how consumers exercise their 14-day right of withdrawal from distance contracts. This requirement, effective June 19, 2026, applies to any trader—including US-based companies—actively selling to EU consumers, creating new compliance obligations around button placement, design standards, data collection, and confirmation processes. Understanding whic

The Council of the European Union adopted a regulation on the reduction of methane emissions in the energy sector (Regulation).

The United States and Saudi Arabia have signed a landmark nuclear cooperation agreement under Section 123 of the Atomic Energy Act, establishing the legal framework for decades of civilian nuclear partnership. This agreement resolves years of debate over nonproliferation conditions and positions US companies to participate in Saudi Arabia's ambitious civil nuclear program. The deal carries significant implications for US engagement in the Middle East, international nuclear commerce, and the global competiti