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ARTICLE · 28 JULY 2026

UK Sanctions Update: Enforcement Momentum Accelerates As OFSI Deploys New Powers And Looks Beyond Russia

Travers Smith LLP
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The UK's Office of Financial Sanctions Implementation (OFSI) has imposed its first financial penalty on a non-UK entity under a new settlement scheme, marking a significant expansion of enforcement reach. Apple Distribution International, an Irish subsidiary of Apple Inc., was fined for making payments to a Russian app developer owned by a designated person, despite the substantive conduct occurring outside the UK.

GlobalGovernment, Public Sector
John Buttanshaw
John Buttanshaw
Harrie Narain
Harrie Narain
Fergus Crutchley
Fergus Crutchley
Oliver Nash
Oliver Nash
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Signs of a marked acceleration in UK sanctions enforcement continue to emerge. In the months since our last update, the Office of Financial Sanctions Implementation ("OFSI") has now deployed its new settlement scheme across multiple cases, imposed penalties on both UK and non-UK entities (including where proactive approaches to establishing ownership and control linkages to designated persons were not taken), and signalled clearly that its enforcement focus will extend beyond Russia to other sanctions regimes - most notably, Iran.

Meanwhile, HMRC has recently demonstrated that export control enforcement remains equally active. The deepening UK-US relationship on sanctions enforcement, underpinned by a formal Memorandum of Understanding ("MoU") and regular strategic exchanges, point to a more coordinated and ambitious posture from both authorities.

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