Russia Sanctions Tracker - UK (2026)

Following its consultation, OFSI has published updated enforcement guidance. This guidance comes into effect from 9 February 2026.

The guidance includes minor updates to a number of chapters, and the significant updates and additions below:

Early Account Scheme, Settlements & Financial Hardship

• Chapter 4 – Early Account Scheme (EAS): Introduction of a new EAS (with a penalty discount of up to 20%), enabling subjects to provide an early factual account of a breach in eligible cases. This section sets out clear eligibility criteria, a step-by-step process, and the information OFSI expects to receive.
• Chapter 6 – Settlement Scheme: Introduction of a new Settlement Scheme (with a penalty discount of 20%). This section sets out how the scheme operates in practice and how it can apply to existing cases.
• Chapter 7 – Financial Hardship: New policy explaining how OFSI will consider exceptional claims of financial hardship, including the burden on the subject to evidence hardship and OFSI’s ability to consider public interest factors.

Enforcement Case Assessment & Discounts

• Chapter 5 – Updated Case Factors: Several case factors have been updated, added, removed or renamed to provide clearer and more consistent assessments.
• Chapter 5 – Four Level Seriousness Model: Replacement of the previous framework with a new four-tiered seriousness model (Levels 1–4), each with indicative outcomes ranging from warning letters to monetary penalties.
• Chapter 6 – Voluntary Disclosure & Cooperation Discount: Introduction of a single penalty discount (up to 30%) for complete voluntary disclosure and co-operation, supported by expanded guidance clarifying what OFSI considers complete and timely cooperation.

Information, Reporting & Licensing Offences

• Chapter 13 – Fixed Monetary Penalties: New section detailing how £5,000 and £10,000 fixed penalties will be applied for relevant offences, including the assessment process, penalty determination, and examples of applicable conduct. This section also expands on OFSI’s interpretation of information offences.

One individual has been removed from the Russia financial sanctions regime and is no longer subject to an asset freeze, trust service and other sanctions:

• Alexey Valeryevich Panferov

General Licence: Humanitarian activity – amendment

INT/2022/1947936

Annex I of the General Licence, which sets out Designated Financial Institutions, was amended to remove Bank FC Otkritie and replace it with BM-Bank, reflecting their merger.

OFSI's FAQs 147-148 were amended accordingly.

General Licence: Payments by Revenue Authorities – amendments

INT/2025/7328184

The General Licence was amended to update the definition of “Revenue Authority” to include the Welsh Revenue Authority and Revenue Scotland.

29 January 2026

OFSI Enforcement Consultation:

Response

OFSI blog post

OFSI has published its response to its public consultation on enforcement. This sets out improvements to make sanctions enforcement more transparent and predictable. These changes are designed to support compliance, give firms greater certainty and help this government apply sanctions in a fair, effective and robust way.

The changes include:

• Improve transparency for industry with a new case assessment matrix and updated guidance to make enforcement decisions clearer and more predictable.
• Enable OFSI to resolve cases more efficiently by introducing settlement and Early Account schemes which will give suitable cases quicker routes to resolution.
• Streamline process for lower-level breaches with set penalties for appropriate information, reporting and licensing offences.
• Strengthen deterrence for serious breaches with plans to double OFSI’s maximum civil penalties, subject to legislation.

28 January 2026

UK Sanctions List: Closure of OFSI Consolidated List and move to a single UK Sanctions List

OFSI's Consolidated List of Asset Freeze Targets has closed and is no longer being updated. The UK Sanctions List is now the only source for all UK sanctions designations.

The Russia list of designations and sanctions notices will also be published on this webpage.

26 January 2026

OFSI announced that on 10 November 2025 it imposed a monetary penalty of £160,000 to a UK banking institution.

The penalty relates to 24 payments processed by the institution, totalling £77,383.39, to a personal account of an individual designated under the Russian financial sanctions regime.

Russian oil: price cap lowered
Joint guidance published by OFSI and HM Treasury

On 15 January 2026, OFSI announced that the Russian oil price cap will be lowered from $47.60 to $44.10 per barrel, effective 23:01 (GMT) 31 January 2026. OFSI has updated the FAQs 154-161 to reflect these changes.

General Trade Licence: Financial Services and Funds related to Fertilisers

The existing 'General trade licence Russia sanctions – financial services and funds related to fertilisers' has been revoked and a new one granted.

The general licence permits the provision of financial services and making funds available to a person connected with Russia for the supply or delivery of specified fertiliser goods either from Russia to a third country, or from Russia to a person in a third country, where they are intended for agricultural use only.