From Wednesday, 28 January 2026, the UK Sanctions List (“UKSL”), published by the Foreign, Commonwealth and Development Office, will act as the sole source of UK sanctions designations made under the Sanctions and Anti-Money Laundering Act 2018 (“SAMLA”). OFSI’s Consolidated List of Asset Freeze Targets (the “OFSI List”) and its
Sophie Davis
Sophie Davis is an associate in Crowell’s London office and advises clients on a range of sanctions, export controls, and trade compliance matters. Sophie has particular experience advising multinational corporations and financial institutions on how to comply with rapidly evolving trade and financial sanctions across a range of EU and UK sanctions regimes, assisting corporate clients with complex sanctions issues arising from their continued operations in, or divestments from, Russia, and supporting clients with licensing applications and responding to investigations.
Sophie also assists companies on compliance with anti-bribery and anti-money laundering laws, foreign direct investment requirements, human rights, environmental and sustainability regulatory requirements. Prior to joining Crowell & Moring, Sophie worked in the international trade and regulatory team in another top international law firm, based in London, as well as for a leading New Zealand law firm.
Treasury Authorizes Transactions with Belarusian Potash Companies
On December 15, 2025, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Belarus General License 13, “Authorizing Transactions Involving Joint Stock Company Belarusian Potash Company, Agrorozkvit LLC, and Belaruskali OAO.” The general license authorizes all transactions prohibited by the Belarus Sanctions Regulations, 31 CFR part 548 (“BSR”), involving Joint Stock Company…
European Commission Revises Dual-Use List: Highlights from the 2025 Update
On November 15, 2025, the implementing regulation updating the EU’s Dual-Use Regulation (Regulation (EU) 2021/821) came into force. The update incorporates editorial refinements for greater clarity and coherence, introduces new entries, and further clarifies some existing ones.
These updates reflect the EU’s efforts to harmonize its export controls with recent decisions and commitments…
Key Takeaways from a Consequential Month of Russia-Related Sanctions
The United States, European Union, and United Kingdom have significantly escalated Russia-related sanctions the past month, including the Trump Administration’s first sanctions directly imposed on Russia. These coordinated actions—which particularly target the Russian energy sector—indicate that Russia sanctions remain on the geopolitical agenda and require multinational companies to remain vigilant in their compliance with those…
EU Adopts 19th Sanctions Package Against Russia
- LNG Import Ban: The EU will prohibit the purchase, import, or transfer, directly or indirectly, of Russian liquified natural gas (LNG) from 25
UK Sanctions Lukoil, Rosneft in Major Russia Sanctions Expansion
On October 15, 2025, the UK announced a significant expansion of its Russia-related sanctions regime, designating Lukoil and Rosneft—Russia’s two largest oil companies—as asset freeze targets.
This is the first time Lukoil and Rosneft have been subjected to full asset freezing sanctions by any of the UK, U.S., or EU, and follows earlier UK measures…
The EU and UK Act to Implement the Iran Sanctions “Snapback”
The snapback of UN sanctions on Iran took effect on September 27, 2025, after the E3 (France, Germany, UK) triggered the mechanism under UN Security Council Resolution 2231 and the Security Council failed to extend sanctions relief. Please see our previous Alert on the snapback process and what this could mean for global businesses.
The…
Client Alert: Impending Deadline for UN Action on Iran: What the “Snapback” of Iran Sanctions Could Mean for Global Business
On August 28, France, Germany, and the UK (the E3) initiated a “snapback” process that will reimpose UN sanctions on Iran on September 27 unless the Security Council acts. On September 19, a resolution to extend sanctions relief failed to receive sufficient votes at the Security Council and was not adopted. If snapback occurs, previously…
The U.S.-UK Trade Deal – So Far
On this 4thof July, Britain was also celebrating. The first country to secure a trade deal with the Trump Administration, the U.K. can indeed celebrate the so-called Special Relationship.
But what exactly is in the deal?
For starters it’s not a free trade agreement in the traditional sense. Rather, it’s more like a…
New UK Sanctions Reporting Duties for Insolvency Practitioners and Other Professionals
In November 2024, the UK Government introduced regulations which granted its financial sanctions regulator – the Office of Financial Sanctions Implementation (“OFSI”) – greater intelligence gathering and enforcement powers. Our previous blog post on these amendments can be found here.
The changes included the extension of mandatory financial sanctions reporting obligations (“…