UK Sanctions and Export Controls Update
Summary
The UK government has updated its sanctions lists and guidance. Amendments were made to the Russia sanctions list regarding Gulbakhor Ismailova and guidance on countering Russian sanctions evasion. Additionally, 22 entries on the Afghanistan sanctions list were amended. A notice regarding resolved transmission issues between export licensing systems and the Customs Declaration Service was also published.
What changed
This update details several key changes to the UK's sanctions and export control landscape. The FCDO amended the Russia sanctions list to add Gulbakhor Ismailova, noting her relation to Alisher USMANOV. Guidance for businesses on countering Russian sanctions evasion has also been updated, providing information on high-risk goods and red flags. Furthermore, 22 entries on the Afghanistan sanctions list have been amended.
Separately, a Notice to Exporters confirms the resolution of transmission issues between the UK's export licensing systems (LITE/SPIRE) and the Customs Declaration Service (CDS), which had caused temporary clearance delays for some consignments. Businesses involved in international trade, particularly those dealing with Russia, Afghanistan, or requiring export licenses, should review these updates to ensure ongoing compliance and to understand any new risks or procedural changes.
What to do next
- Review updated Russia sanctions list entry for Gulbakhor Ismailova.
- Review updated guidance on countering Russian sanctions evasion.
- Review amended Afghanistan sanctions list entries.
- Note the resolution of export licensing system transmission issues with CDS.
Source document (simplified)
March 20, 2026
UK Weekly Sanctions Update - Week of March 16, 2026
Jason Hungerford, Kirsty Morris, Mihira Patten, Findley Penn-Hughes, Paul Whitfield-Jones Mayer Brown + Follow Contact LinkedIn Facebook X Send Embed
In this weekly update, we summarise the most notable updates in the UK sanctions world.
RUSSIA SANCTIONS
- UK Government amends one entry on the UK sanctions list under the Russia sanctions regime: On March 12, 2026, the FCDO amended the listing for Gulbakhor Ismailova under the Russia sanctions regime. The variation adds that there are reasonable grounds to suspect Gulbakhor Ismailova is the sister of Alisher USMANOV, who is an involved person under the Russia (Sanctions) (EU Exit) Regulations 2019 and was designated by the UK on 3 March 2022. (Sanctions Notice, Russia: 12 March 2026; The UK Sanctions List - GOV.UK)
- UK Government updates guidance on countering Russian sanctions evasion: On March 12, 2026, the UK Government updated their guidance intended to support UK businesses in understanding Russian circumvention practices and in reducing the risk of their business being targeted by those seeking to evade sanctions. This guidance provides information regarding goods at greater risk of being diverted to Russia, red flags indicators of sanctions evasion, and suggestions for enhanced due diligence. (Countering Russian sanctions evasion - guidance for businesses - GOV.UK)
AFGHANISTAN
- UK Government amends 22 entries on the UK sanctions list under the Afghanistan sanctions regime: On March 11, 2026, FCDO amended 22 entries on the UK sanctions list under the Afghanistan sanctions regime. (Sanctions Notice, Afghanistan: 11 March 2026; The UK Sanctions List - GOV.UK)
OTHER
UK Government publishes Notice to Exporters 2026/06 regarding transmission issues between LITE/SPIRE and CDS: On February 27, 2026, the Export Control Joint Unit (ECJU) published Notice to Exporters 2026/04 advising exporters of temporary transmission issues between the UK's export licensing systems (LITE and SPIRE) and the Customs Declaration Service (CDS). As a result, some consignments arriving at the border may not be cleared in the usual way if the relevant licence information has not reached CDS. On March 13, 2026, this new notice has been published to confirm that this issue is no longer subject to ongoing investigation and has been resolved. (NTE 2026/06: resolved licence transmission issues with Customs Declarations Service (CDS) - GOV.UK)
UK Government publishes Notice to Exporters advising of upcoming updates to UK strategic export controls: On March 11, 2026, the Export Control Joint Unit (ECJU) published Notice to Exporters 2026/05 providing notice that the open general export licence (OGEL) military goods: collaborative Project Typhoon has been updated. Project Typhoon is a collaborative programme between the German, Italian, Spanish and UK governments for the development, production, and sale of a European fighter jet. This update includes Turkey as a permitted destination and adds a condition to the OGEL requiring the licence reference in the form ‘GBOGE 20XX/XXXXX’ to be entered in the UK’s customs declarations system. (NTE 2026/05: update to open general export licence - GOV.UK)
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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
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