Sanctions Synopsis: April 2026 Edition

By Leonore Carron-Desrosiers

The past few months brought notable sanctions developments, including:

1. OFSI’s Strategy for 2026-2029.
2. New OFSI guidance.
3. Recent enforcement actions.
4. A Court of Appeal judgment on ECHR jurisdiction in sanctions cases.

If any topics are of interest please do not hesitate to contact us.

OFSI’s Strategy: 2026-2029

On 15 April 2026, OFSI published its strategy for 2026-2029. The report marks the 10-year anniversary of OFSI, reflects on OFSI’s activities between 2021 and 2026, and sets out OFSI’s plan for the next three years. Notably, the report identifies as key areas of focus new technologies and the use of crypto assets to circumvent sanctions. As part of its targets, OFSI will aim to close 50% of licensing cases within 6 months and to submit 90% of new enforcement investigations for decision within 18 months of commencement.

New OFSI guidance

On 13 March 2026, OFSI published a blog post explaining how OFSI assesses “reasonableness” when considering license applications. Notably, in relation to applications under the legal fees licensing ground, OFSI will now require an independent Costs Draftsperson’s Report to be submitted as part of a license application when: (i) within a 6-month period, the total legal fees exceed £2,000,000 (inc. VAT) for law firms and £1,000,000 (inc. VAT) for counsel; and (ii) where the license application covers a period longer than 6 months, the same thresholds will be applied on a pro rata basis to reflect the length of the period covered. Applicants can also choose to provide such a report proactively if the matter is relatively complex.

The blog post also provides detailed guidance in relation to applications under the maintenance of frozen funds and economic resources licensing ground, for which applicants are encouraged to provide an independent expert report where the requested payment is high-value.

More generally, OFSI recommends that evidence to demonstrate reasonableness should be dated within the past 6 months (otherwise the applicant will be expected to explain why more recent evidence could not be obtained and why the evidence is still reliable).

Recent enforcement actions

On 10 November 2025, OFSI imposed a £160,000 fine on the Bank of Scotland for breaching sanctions by processing payments to and from a personal current account held by an individual designated under the Russia Regulations, and published details of the penalty in January 2026. On 23 February 2026, OFSI published a blog post on this case, identifying key lessons for firms, including in terms of screening processes, automation and internal training procedures.

On 19 March 2026, OFSI fined Apple Inc’s Irish subsidiary, Apple Distribution Internation Ltd (“ASI”), £390,000 for making funds available in breach of sanctions to Russian app-developer Okko, which is owned by a UK-designated person under the Russia sanctions. Information about the penalty can be found here. ADI is, among other activities, responsible for instructing payment transactions for revenues earned by software developers who have placed their software applications on the online ‘App Store’ marketplace. Such payments are made using ADI funds held in a UK-based bank account that is controlled by ADI. Key take-aways from this case are that (i) non-UK firms using UK financial institutions to conduct payments will fall within the UK’s jurisdiction even if the non-UK firm is managing the account directly from outside the UK; and (ii) ADI failed to cancel the relevant payment instructions and was held responsible for the payments in breach of sanctions even though it had relied on corporate affiliates to implement relevant payment processes and the relevant sanctions screening and due diligence measures. This is also the first OFSI case resolved by means of settlement.

A Court of Appeal Judgment on ECHR jurisdiction in sanctions cases

On 26 February 2026, the Court of Appeal dismissed Dana Astra’s appeal which sought to overturn the High Court decisions refusing to delist Dana Astra from the UK’s Belarus Sanctions. Dana Astra was added to the sanctions list in 2020 and re-listed in 2023 pursuant to s.38 of the UK Sanctions Act for being “complicit in the repression of civil society” by sponsoring the Belarusian National Olympic Committee and benefiting from supporting the Belarus Government.

The High Court had rejected Dana Astra’s arguments that (i) the designation was disproportionate and therefore unlawful under European Convention on Human Rights (“ECHR”); and (ii) the designation was irrational at common law because the Claimant considered itself hostile to the Belarus Government. The Court of Appeal upheld the first instance decision, finding Dana Astra was not within the jurisdiction of the UK for the purpose of the ECHR since it had no property in the UK and insufficient good will in its business. In any event, the Court found that the sanction was not disproportionate and that the designation was rational. The decision suggests that the UK Courts will continue to take a strict approach to sanctions and impose a high threshold on challenges to designations.

The full judgment can be found here: Dana Satra v Secretary of State for Foreign, Commonwealth and Development Affairs [2026] EWCA Civ 160