UK Weekly Sanctions Update - Week Of February 2, 2026

In this weekly update, we summarise the most notable updates in the UK sanctions world. If you have any questions in respect of any of the developments set out below, please do not hesitate to contact a member of our London Global and Government Trade team listed above.

Russia sanctions

• OFSI amends General Licence for Humanitarian Activity: On February 5, 2026, OFSI amended General Licence INT/2022/1947936, which authorises a Relevant Person to ensure the timely delivery of humanitarian assistance activity in relation to the conflict in Ukraine and non-government controlled Ukrainian territory, subject to certain terms and conditions. This General Licence was amended to reflect Bank Otkritie's merger with BM-Bank. This General Licence took effect on July 7, 2022. ( https://assets.publishing.service.gov.uk/media/698437f813622473b51caa36/General_Licence_INT-2022-1947936.pdf)
• OFSI amends General Licence for Payments by Revenue Authorities:On February 2, 2026, OFSI amended General Licence INT/2025/7328184, which authorises a Revenue Authority to make Permitted Payments to UK Designated Persons frozen UK bank accounts, subject to certain terms and conditions. This General Licence was amended to include the Welsh Revenue Authority and Revenue Scotland definitions . This General Licence took effect on September 26, 2025 ( https://assets.publishing.service.gov.uk/media/697cc58101dffa646558004e/Revenue_Authorities_
  Payments_PN_INT.2025.pdf)

Iran (nuclear) sanctions

• UK Government adds 11 entries to the UK sanctions list under the Iran sanctions regime: On February 2, 2026, the FCDO added one entity and 10 individuals to the UK sanctions list under the Iran (Sanctions) regime. According to the UK Government, the sanctions were announced in response to those who have committed human rights violations in Iran and follows recent human rights sanctions imposed by the EU and the US. The UK Government said in a press release that Iran's Law Enforcement Forces are responsible for serious violations of human rights in Iran, namely the right to freedom of expression and peaceful assembly. ( https://www.gov.uk/government/news/uk-announces-sanctions-against-perpetrators-of-human-rights-violations-in-iran#:~:text=The%20UK%20already%20has%20imposed,place%20for%20Human%20Rights%20violations;
  https://assets.publishing.service.gov.uk/media/6980ab97ec71a16669612e09/Sanctions_Notice__2_
  February_2026__Iran.pdf)

Sudan Sanctions

• UK Government adds 6 entries to the UK sanctions list under the Sudan sanctions regime: On February 5 2026, the FCDO added 6 individuals to the UK sanctions list under the Sudan regime. According to the UK Government, the individuals are"suspected of committing atrocities in the war in Sudan, or fuelling the conflict through the supply of mercenaries and military equipment."( https://www.gov.uk/government/news/uk-imposes-fresh-sanctions-to-dismantle-sudans-war-machine)

Other

• UK Government amends Financial Sanctions FAQs: On February 5, 2026, OFSI updated FAQs 147-148 to reflect the amendment of OFSI General Licence INT/2022/1947936. The updated FAQs now provide guidance regarding General Licences that do not reflect Bank Otkritie's merger with BM-Bank. ( UK Financial Sanctions FAQs - GOV.UK)
• UK Government amends Financial Sanctions FAQs: On February 2, 2026, OFSI updated FAQ 133 to provide further guidance on reporting obligations when refusing business to a Designated Person. Relevant Firms have a legal obligation to report to OFSI when they identify a Designated Person during the course of business, and the updated FAQ now provides scenario examples of when OFSI does and does not expect to receive a report. ( https://www.gov.uk/government/publications/uk-financial-sanctions-faqs/uk-financial-sanctions-faqs)

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This Mayer Brown article provides information and comments on legal issues and developments of interest. The foregoing is not a comprehensive treatment of the subject matter covered and is not intended to provide legal advice. Readers should seek specific legal advice before taking any action with respect to the matters discussed herein.