UK Government Implements New Sanctions Enforcement Recommendations

In May 2025, the UK government published the Cross-Government Review of Sanctions Implementation and Enforcement policy paper (“Cross-Government Review”). Led by the Foreign, Commonwealth and Development Office (FCDO), and supported by key sanctions departments and agencies across the UK government, the Cross-Government Review identifies steps to improve and facilitate compliance with sanctions, increase the deterrent effect of enforcement, and strengthen the government’s enforcement toolkit.

The Cross-Government Review sets out 10 conclusions and associated actions for implementation by the UK government, including updates to sanctions pages and statutory guidance, greater clarity on compliance rules, a government-wide sanctions enforcement strategy, and public consultations on a civil settlement scheme and a fast-track penalty process for financial sanctions breaches. Several of these commitments have already been implemented.

New Sanctions Enforcement Action Page
On November 3, 2025, the UK government launched a new Sanctions enforcement action page on GOV.UK—a single landing page consolidating enforcement outputs and “key lessons for industry” from the Office of Financial Sanctions Implementation (OFSI), the National Crime Agency (NCA), the Office of Trade Sanctions Implementation (OTSI) and His Majesty’s Revenue and Customs (HMRC). These bodies collectively oversee civil and criminal enforcement under the UK’s financial sanctions, trade sanctions and export controls regimes.

This initiative implements one of the headline commitments from the Cross-Government Review—namely, to publish easily accessible, consolidated enforcement information and to do so regularly to take advantage of “teachable moments” that deter future non-compliance.

As enforcement responsibility in the UK is fragmented across multiple bodies, outcomes of their respective enforcement actions are published separately through different channels. The new hub materially improves accessibility for businesses navigating overlapping financial, trade and export control regimes.

In addition to enforcement updates, the page aggregates related materials such as case studies, press releases, blog posts and annual reviews issued by these enforcement bodies, as well as organizations from across government such as the Export Control Joint Unit.

The government has indicated that the page will be updated on a regular basis as new enforcement actions and guidance are released. Users can also subscribe to email updates to get notified of these changes here.

Single Sanctions List
The UK government has also committed to consolidate the UK’s two sanctions lists, in response to industry feedback that a single list will remove duplication of effort and simplify checks of who is subject to UK sanctions.

On January 28, 2026, the Consolidated List of asset freeze targets published by OFSI (covering the UK’s asset freeze and investment ban designations) will be retired.

The existing UK Sanctions List, published by the FCDO, which covers all financial, immigration, trade or transport sanctions designations, will become the sole authoritative sanctions list. Filtering by asset freeze targets will continue to be available and the search tool will receive functional upgrades.

In preparation for this change, all compliance processes which rely on the Consolidated List should be updated prior to January 28, 2026, to utilize the UK Sanctions List instead.

Clearer and More Accessible Guidance
In June 2025, the UK government began to deliver on its commitment to comprehensively update sanctions pages and statutory guidance across government websites in an effort to improve clarity and structure. This was kickstarted by the release of a new, searchable Sanctions Hub page, an expanded selection of industry guidance published on the Russia sanctions regime, and an improved collection of guidance on the UK’s various sanctions regimes.

Consultation on Civil Settlement and Fast-Track Penalties
On July 22, 2025, OFSI ran a consultation on improving civil enforcement processes for financial sanctions, which closed on October 13, 2025.

Reflecting the commitments in the Cross-Government Review, OFSI has proposed, among other things, to introduce a civil settlement scheme for breaches of financial sanctions (much like the comparable scheme that exists in the U.S. and the comparable scheme that exists in relation to breaches of UK export controls), allowing OFSI to propose settlements in lieu of monetary penalties where appropriate in order to quickly resolve civil financial sanctions cases and aid deterrence.

As of writing, OFSI is still analysing feedback on the consultation and has yet to publish a response.

Interestingly, the consultation does not include proposals on the introduction of an accelerated civil penalty process for certain financial sanctions, as was also recommended in the Cross-Government Review, which may follow in a later consultation.

Whistleblower Protections
Another of the commitments set out in the Cross-Government Review was to expand whistleblower legislation to cover reports of financial, transport and certain trade sanctions breaches to relevant government departments. This was implemented in June 2025 through the entry into force of the Public Interest Disclosure (Prescribed Persons) (Amendment) Order 2025.

Further detail on this development and its implications for businesses is available in our earlier article.

Conclusions and Expectations for Further Measures
While the UK government has made tangible progress in implementing the conclusions of the Cross-Government Review, several headline commitments remain outstanding—most notably, the forthcoming government-wide sanctions enforcement strategy. This strategy, once published, is expected to clarify the range of non-compliance scenarios, the corresponding enforcement pathways, and the factors influencing penalty outcomes.

Businesses should also expect incremental reforms spurred by some of the more generic commitments—for instance, those aimed at simplifying reporting or increasing engagement with sectors less familiar with sanctions compliance.

Taken together, these developments signal a more coordinated and proactive approach to sanctions enforcement. Firms should ensure that sanctions screening, governance frameworks and internal escalation procedures are aligned with the evolving UK enforcement landscape.

The authors would like to thank trainee solicitor Samson Verebes for his contributions to this blog.

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