Policy & Compliance
Sanctions developments and key implications for UK logistics sector
Some of the notable cases resulted in multiple penalties imposed on companies for making funds available to a designated person under the Russia sanctions regime. Signi fi cant penalty A first-of-a-kind penalty was issued to another business for an information offence breach, emphasising the importance of responding fully and promptly to regulatory information requests. One of the high street banks received a significant penalty imposed after processing payments for a designated individual. A settlement of over £1 million was reached with a UK exporter supplying goods to Russia in breach of sanctions. In addition, the first criminal conviction for violating the UK financial sanctions related to Russia has taken place, showing a tougher approach to law enforcement. For the UK logistics sector, the key lessons from 2025 are clear; sanctions screening should be integrated into operational processes, shipment level due diligence must be strengthened, and compliance governance frameworks must be robust enough to withstand increasing regulatory scrutiny and enforcement activity.
Sanctions enforcement activities increased signi fi cantly during 2025. Forwarders should make sure that sanctions screening is integrated into their operational processes
2 025 proved to be an eventful year with the UK intensifying its sanctions regime, particularly against Russia and Iran. Some forwarders encountered increased compliance obligations and operational disruption challenges. The message from government was clear, freight supply chains play an important role in sanctions evasion and regulators expect robust due diligence. Dedicated guidance To assist the industry, in November 2025 the Office of Trade Sanctions Implementation (OTSI) published dedicated guidance for the freight and shipping sector on countering Russian sanctions evasion. The document sets out red flag indicators, lists categories of goods at high risk of diversion to Russia, and outlines best practice due diligence steps. It complements earlier general evasion guidance and has been specifically aimed at freight forwarders, carriers, customs intermediaries and other actors facilitating the movement of goods.
On the same day, a new central Sanctions Enforcement Action page on GOV.UK was published. The web portal consolidates case studies, penalty notices and “key lessons for industry” from the Office of Financial Sanctions Implementation (OFSI), Office of Trade Sanctions Implementation (OTSI), HM Revenue & Customs (HMRC) and the National Crime Agency (NCA). In parallel, the government transitioned to a single UK Sanctions List as the definitive source of designations, replacing the former Consolidated List, making compliance information more accessible. Regulatory authorities also moved to strengthen the enforcement framework. Updated guidance introduced revised penalty-calculation methodologies, early settlement mechanisms, and proposals to significantly increase maximum monetary penalties. Sanctions enforcement activities increased significantly during 2025, with the OFSI reporting approximately 240 active investigations as of April 2025.
“ In November 2025 the Office of Trade Sanctions Implement- ation (OTSI) published dedicated guidance for the freight and shipping sector on countering Russian sanctions evasion
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