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UK sanctions review 2024-25: guidance-led, enforcement-weak; effective deterrence needs OFSI resourcing, public-private partnership, single reporting point and whistleblower incentivisation

Published on: 01 July 2025

Published by a Law360 reporter
Legal News
Table of contents
  • Facilitating compliance
  • Increasing deterrence
  • Invigorating cross-government toolkit
  • Conclusion
Article summary

Launched in October 2024

Unveiled in October 2024, the review is led by the Foreign, Commonwealth and Development Office in partnership with sanctions departments and agencies — HM Treasury (HMT), the Department for Business and Trade (DBT), the Department for Transport (DfT), HM Revenue and Customs (HMRC) and the National Crime Agency (NCA). It advances recommendations designed to facilitate compliance with UK sanctions, strengthen deterrence against breaches, and refresh the cross‑government sanctions enforcement toolkit. In our analysis, we examine these recommendations and determine that they are unlikely to fulfil the UK government’s ambitions, as articulated in the review: to ‘support the private sector to understand and comply with sanctions’ while ‘punish serious breaches with large fines or criminal prosecution’...

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