Sanctions Synopsis: January 2026 Edition

By Leonore Carron-Desrosiers and Mikhail Vishnyakov

The past few months brought notable sanctions developments, including:

  1. The UK moves to a single Sanctions List.
  2. OFSI amends the Legal Services General License.
  3. The UK government publishes a new sanctions enforcement page.
  4. The Jersey Court of Appeal upholds a first-instance decision to enforce an arbitral award in favour of a bank majority-owned by a sanctioned entity.

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

  1. The UK moves to a single Sanctions List

From 28 January 2026, the UK’s sanctions lists will be consolidated into a single list. The sanctions lists are currently split into the UK Sanctions List published by the FCDO and the Consolidated List of Asset Freeze Targets published by OFSI. From 28 January 2026, the Consolidated List of Asset Freeze Targets will no longer be updated and the UK Sanctions List (link here) will become the only source of UK sanctions designation.

  1. OFSI amends the Legal Services General License

The Legal Services General Licence, which allows UK law firms, legal advisers and counsel to receive payments from people and entities sanctioned under 26 sanctions regimes without a specific license, was updated on 17 December 2025 to clarify that “legal services” include legal advice and/or representation in relation to dispute resolution and is not limited to litigation.

  1. The UK Government publishes a new sanctions enforcement page

The UK sanctions authorities (FCDO, HMRC, NCA, OFSI and OTSI) jointly published a new ‘Sanctions enforcement action’ page on 3 November 2025. The page lists monetary penalties, prosecution outcomes and disclosure notices imposed by OFSI, the NCA, OTSI and HMRC.

This is a helpful resource to monitor developments in relation to sanctions enforcement across the various public bodies and agencies.

  1. The Jersey Court of Appeal upholds a first instance decision to enforce an arbitral award in favour of a bank majority-owned by a sanctioned entity

In November 2024, the Royal Court of Jersey allowed OWH SE i.L (“OWH”), a German bank majority-owned by sanctioned Russian entity VTB Russia (“VTB”), to enforce an arbitral award of c. €213 million against RTI Limited (“RTI”), a Jersey company part of the Rusal Group. The initial dispute arose after RTI refused to meet margin calls from OWH under a 2019 currency swap agreement because it feared breaching Jersey sanctions (given VTB’s designation in early 2022).

RTI appealed the Royal Court’s decision. RTI argued that enforcement contravened public policy and that it should benefit from retrospective immunity because its actions were reasonably believed to be necessary for sanctions compliance and should be allowed by Article 46A of the Sanctions and Asset-Freezing (Jersey) Law 2019 (introduced in June 2022 after RTI’s refusal to pay).

The Jersey Court of Appeal dismissed the appeal unanimously and found that sanctions-related immunity did not retrospectively apply to acts before June 2022. It also rejected RTI’s argument that enforcement would be unfair. The Court of Appeal held that refusing enforcement would undermine contractual certainty and considered that RTI had acted unreasonably in refusing payment.

The judgment may be found here: RTI Limited v OWH SE i.L. 15-Dec-2025