Sanctions Synopsis: April 2025 Edition

By Mikhail Vishnyakov, Emily Davies and Leonore Carron-Desrosiers

This sanctions synopsis captures:

New General Licence for arbitration fees and costs.
OFSI’s series of “Threat Assessment Reports” relating to Financial Sanctions.
OFSI’s “Annual Review 2023-24: Engage, Enhance, Enforce.”
US class action against Kazakh bank for sanctions non-compliance.
The High Court’s dismissal of an application for further information regarding sanctions designation.

If any of these topics are of interest, please do not hesitate to reach out.

New General Licence for arbitration fees and costs

On 28 March 2025, OFSI issued General Licence INT/2025/5787748 under Regulation 64 of the Russia Regulations 2019 and Regulation 32 of the Belarus Regulations 2019.

This new general license allows designated persons to make payments to Arbitration Associations and Arbitrators to cover fees and expenses for their arbitration services. These include, but are not limited to, appointment fees, security deposits and advance payments, fees associated with hearings, tribunals, preparing awards, and other expenses or administrative charges. The license also permits Arbitration Associations and Arbitrators to direct, receive or use such payments. In addition, the license allows payments to be made to the designated person’s representatives and legal representatives for the purpose of paying arbitration costs. However, the general license does not permit any funds to be made available to the designated person.

The license is limited to a total amount of £500,000 (including VAT where applicable) per arbitration.

OFSI publishes a series of “Threat Assessment Reports” relating to Financial Sanctions

OFSI has published a series of reports that outline OFSI’s assessment of threats to sanctions compliance across a range of sectors. These include OFSI’s “Key Judgments”, which assess sector-specific concerns regarding sanctions compliance, as well as common compliance issues, red flags, case studies and further resources. Individuals and entities working in the relevant sectors are encouraged to consider these reports as part of their ongoing compliance and due diligence. The reports are intended “to assist stakeholders with prioritisation as part of a risk-based approach to compliance”.

OFSI published the following reports as part of the “Threat Assessment Reports” series:

The Financial Services Threat Assessment Report (February 2025).
The Legal Services Threat Assessment Report (April 2025).
The Property and Related Services Threat Assessment Report (April 2025).

OFSI publishes its “Annual Review 2023-24: Engage, Enhance, Enforce”

In March 2025, OFSI published its Annual Review for the year 2023-24 titled “Engage, Enhance, Enforce”. Among key takeaways from the previous year, OFSI identified the monetary penalty against Integral Concierge Services Limited in August 2024, the coalition on the G7+ oil price cap ‘OPC Compliance and Enforcement Alert’ in February 2024, and the work of OFSI’s ‘Money Laundering Intelligence Taskforce’ to further law enforcement in the financial sector.

The Annual Review states that, as of December 2024, £25.03 billion worth of assets frozen in relation to the Russia Regime have been reported to OFSI since 2022. It is noteworthy that “The majority of suspected breach cases recorded by OFSI in 2023-24 relate to the financial sectors, followed by the legal sector”. In addition, OFSI announced that “A number of enforcement cases are expected to result in public outcome in 2025”.

US class action against Kazakh bank for sanctions non-compliance

On 19 December 2024, an investor filed a class action complaint in the US against Kaspi.kz, a company which, according to the complaint, owns Kaspi Bank, described therein as “one of the largest and systematically important financial institutions in Kazkhastan”. This recent class action suggests that investors may be able to bring claims against financial institutions for making misleading statements regarding sanctions compliance.

Read Mikhail Vishnyakov’s analysis of this case and whether a similar claim could be brought in the UK, in his article in the Law Gazette here: Securities litigation: Sanctions, class actions and regulations | Law Gazette .

High Court dismisses application for further information regarding sanctions designation: Sarvar Ismailov v Secretary of State for Foreign Commonwealth and Development Affairs [2025] EWHC 863 (Admin)

The Claimant was designated under the Russian Regulations and sought to challenge his designation in July 2024. In October 2024, the FCDO filed grounds for contesting the Claimant’s designation challenge.

The Claimant sought an order for the FCDO to provide further information regarding its grounds for contesting the Claimant’s designation challenge. The Claimant argued that his designation had been motivated by political considerations rather than a faithful application of the statutory criteria. The Claimant alleged that there may have been an attempt by an unidentified public body (which the Claimant’s counsel suggested might have been the NCA) to lobby the FCDO in favour of his designation.

The disclosure previously provided by the FCDO included an email chain, which suggested that an unidentified public body had made a ’proposal’ to the FCDO that the Claimant be sanctioned but that the information provided had been deemed insufficient by the FCDO. The Claimant’s application was dismissed on the basis that, as evidenced by the disclosure already provided by the FCDO, the relevant communications with the public body in question had not formed part of the FCDO’s decision-making process. The Court therefore did not accept that the FCDO’s decision-making process had been tainted. Instead, the Court found that there was nothing surprising or troubling about the fact that “the respective sanctions bodies of states regularly communicate with each other and with other public authorities to ensure sanctions can be most effective.” The Court further rejected the Claimant’s application on the basis it was “not directed to (or “about”) any aspect of the Defendant’s pleaded response” and therefore did not fall within the scope of disclosure applications under the applicable procedural rule.