March 26, 2026

UK Weekly Sanctions Update - Week of March 23, 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

• OFSI issues General Licence for activity in relation to the supply, purchase, transportation or delivery of Kazakh oil: On 18 March 2026, OFSI issued General Licence INT/2026/9247168 which authorises PJSC Transneft and its subsidiary to conduct activities in connection with the supply, purchase, transportation or delivery of Kazakh oil, provided that the Kazakh oil is not owned by a person connected with Russia, and that the Kazakh oil is only being loaded in, departing from, or transiting through Russia, subject to certain terms and conditions. This General Licence expires on 18 March 2028. (https://assets.publishing.service.gov.uk/media/69bc0d1f8006048065f73d09/GLDoc-KazakhOilExports.pdf?utmcontent=&utmmedium=email&utmname=&utm_source=govdelivery)
• UK Government varies UK Sanctions List entries under the Russia sanctions regulations: On 17 March 2026, the FCDO varied the entry for Viatcheslav Kantor, to reflect his activities in the Russian chemicals and extractive sectors and his position as Chairman of the Coordinating Board of PJSC Acron. It also corrected the entries for JSC BBR Bank, Transcapitalbank, JSCB FORA-BANK, Nikolay Dmitrievich Peskov and removed the entry for German Belous under the Russia (Sanctions) (EU Exit) Regulations 2019. (https://assets.publishing.service.gov.uk/media/69b96d91635612b767a4665a/Sanctions_Notice__ Russia17March2026.pdf) (https://assets.publishing.service.gov.uk/media/69b8276ce2719934bb53a2e1/Sanctions_Notice__ Russia_16March_2026.pdf)
• OTSI updates its guidance for businesses on countering Russian sanctions evasion: On 17 March 2026, the Office of Trade Sanctions Implementation updated its guidance, reminding businesses that they are responsible for assessing their sanctions risk exposure and implementing appropriate safeguards. The updated guidance expands the list of goods considered at higher risk of circumvention to include crushing or grinding machines for mineral substances, enamels and lacquers, and certain heterocyclic compounds. The updated guidance also adds Israel to the list of third countries warranting enhanced due diligence to prevent re-export of at-risk products to Russia. (https://www.gov.uk/government/publications/countering-russian-sanctions-evasion-and-circumvention/countering-russian-sanctions-evasion-guidance-for-exporters#foreword)

CENTRAL AFRICAN REPUBLIC

• UK Government updates Central African Republic (CAR) sanctions guidance: On 18 March 2026, the UK Government updated its statutory guidance on CAR sanctions under the Central African Republic (Sanctions) (EU Exit) Regulations 2020 to reflect the Central African Republic (Sanctions) (EU Exit) (Amendment) Regulations 2025, which removed the CAR arms embargo and implemented UN Security Council resolutions. The updated guidance addresses trade sanctions and export provisions that remain in place post-embargo, introduces a new section on director disqualification orders preventing designated persons from serving as UK company directors, and explains the exceptions under Part 6 of the 2020 Regulations, including the UN humanitarian exception. (https://www.gov.uk/government/publications/central-african-republic-sanctions-guidance/central-african-republic-sanctions-guidance)

OTHER

• OFSI publishes video guidance on designated persons: On 20 March 2026, OFSI published a video providing an overview of how to find out who is designated under UK sanctions regimes, how OFSI and FCDO come together when there are new designations, and what firms should do once an individual has been designated. (https://www.gov.uk/guidance/ofsi-video-guidance#finding-out-who-is-a-designated-person)

• OFSI publishes a blog post outlining its updated approach to assessing “reasonableness” when considering licence applications under the UK’s financial sanctions regimes: On 16 March 2026, OFSI noted that some licence applications for legal fees under the legal fees licensing ground involve requests running into millions of pounds, and has emphasised that applicants must demonstrate the reasonableness of such fees. To support its assessment, OFSI will now require an independent Costs Draftsperson's Report where the total legal and Counsel fees exceed £2 million (including VAT) within any six-month period, or £1 million where Counsel is instructed directly. (https://ofsi.blog.gov.uk/2021/06/30/reasonableness-in-licensing/)
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• UK Weekly Sanctions Update - Week of March 16, 2026
• UK Weekly Sanctions Update - Week of March 2, 2026
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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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