Sanctions – Updated Advisory Note

1 July, 2025

The CLC has today published an updated Advisory Note on compliance with the UK Sanctions Regime. It is in force now.

This is a comprehensive update to the advisory note and we would urge CLC practices and individuals we regulate of the vital need to be aware of these requirements and of adhering to them.

Recent changes to sanctions include:

• OFSI published a threat assessment for the legal services sector in April 2025 which identified that there has been, “…widespread misuse of complex structures and trusts to hide asset ownership by Russian Designated Persons (DPs)”. These corporate structures have included companies, foundations, trusts and limited partnerships. The assessment explicitly states that “family members and associates of Russian DPs may serve a variety of roles in these structures.”
  
• According to the same threat assessment, Trust and Company Service Providers (TCSPs) may not be reporting all breaches and OFSI conclude that underreporting in this area is “highly likely”.
  
• The UK and the EU announced a new package of sanctions  in May which was aimed at Russia’s military, energy and financial sectors and included some notable, key measures:
  
  A. Targeting of Russia’s “shadow fleet” of vessels used to bypass sanctions and ensure that Russia can continue oil exports. On 9 May 2025 the UK announced sanctions on 100 vessels which form the core of the shadow fleet and also 18 vessels were added on 29 May 2025.
  
  B. Asset freezes were imposed on 46 financial institutions, including the St. Petersburg Currency Exchange and the Russian Deposit Insurance Agency, as well as certain Russian corporate registrars

Read the full Advisory Note