From a slew of new sanctions against Russian entities to higher penalties against companies breaching sanctions, Lexology PRO analyses enforcement activity across sanctions to identify key risks and trends for businesses.
The data in this article is based on Lexology PRO’s Scanner, our automated regulatory monitoring tool covering 18 regulatory areas and tracking over 1500 regulatory sources. Full details on Scanner’s regulatory coverage can be found here.
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Enforcement in this series includes any action regulators have taken as part of their enforcement powers, including active investigations, audits, decisions, fines, penalties, settlements, and/or orders. This report covers data – primarily agency announcements – released between 1 November 2024 and 1 November 2025.
Sanctions-related enforcement in this article includes sanctions issued by authorities as well as actions taken against companies for breaching sanctions regimes.
There was significant sanctions activity over the last 12 months, with key regulators and authorities continuing to issue new sanctions against individuals and entities, and penalise businesses for breaching restrictive measures.
In a similar pattern to last year, Scanner data shows US authorities and regulators were the most active in sanctions enforcement by quite some margin. US sanctions primarily focused on Russia, including key oil and gas companies that fund the Kremlin’s war machine.
G7 countries make up a large part of the list of most active jurisdictions. The European Union (EU) continued to pressure Russia with restrictive measures and sanctions packages. Meanwhile, Switzerland kept pace with its neighbouring countries, implementing numerous bouts of EU and United Nations (UN) Security Council sanctions, and the UK frequently worked with G7 partners to impose restrictive measures on bad actors.
US agencies have led the charge, using sanctions and enforcement as strategic tools to address national security concerns, disrupt illicit financial networks, and respond to ongoing conflicts in Ukraine and Gaza.
Other major regulators have mirrored this assertive posture. Authorities in the EU and Switzerland have prioritised financial system integrity and tighter controls to prevent circumvention. Canada and Japan stepped up their sanctions against Russia, underscoring a coordinated response among G7 nations to maintain pressure on Moscow.
Similar to last year, Iran emerged as the most heavily targeted jurisdiction by US Treasury sanctions enforcement. A pivotal moment came in July 2025, when the Treasury’s Office of Foreign Assets Control (OFAC) unveiled its largest sanctions package against Iran since 2018, designating dozens of individuals, entities, and vessels tied to a sprawling maritime empire.
Russia also remained a central focus. In October 2025, OFAC sanctioned Russia's two largest oil companies in yet another push to put pressure on President Vladimir Putin.
Treasury activity has not been limited to just issuances of new sanctions, but also penalties and actions against companies found to have breached US sanctions regimes. In a recent example, OFAC fined San Francisco-based venture capital fund GVA Capital US$216 million for ties to Russia.
In the past year, the European Council has intensified its sanctions campaign against Russia, adopting five additional packages – from its 15th to 19th – since November 2024. These measures broadened restrictions on energy exports, advanced technology, and financial services, aiming to further constrain Moscow’s ability to fund its military operations.
Iran also came under renewed scrutiny after the UN triggered its snapback mechanism, reinstating sanctions previously lifted under the 2015 nuclear agreement. The EU quickly aligned with this move, reviving its own restrictive measures, which include bans on Iranian cargo flights and sweeping sanctions on key Iranian financial institutions.
Throughout 2025, the UK's sanctions regime mirrored the EU's focus on Russia. The UK imposed over 100 new Russia sanctions in February 2025, representing its largest package since the early days of the invasion.
The UK ramped up sanctions against Russia’s ‘shadow fleet,’ meaning the UK has now targeted more oil tankers than any other country. Designations in October included major Russian energy companies Rosneft and Lukoil, alongside international entities facilitating oil transportation.
Enforcement against companies breaching sanctions intensified in parallel. For instance, HM Revenue & Customs securing its largest compound settlement for Russia sanctions breaches in May 2025 – a penalty exceeding £1.1 million (US$1.4 million) against a UK exporter.
Swiss State Secretariat for Economic Affairs: which countries were targeted most?
Switzerland’s State Secretariat for Economic Affairs (SECO) is responsible for issuing sanctions in the country, which often mirror EU measures. On 29 October 2025, SECO implemented the EU’s 18th sanctions package against Russia, and in April adopted further EU restrictions, including an expanded advertising ban on Russian media.
SECO also acts independently to the EU, adding new sanctions against Russian entities in August 2025, while lifting sanctions on Syria in June, highlighting its dual role in aligning with EU policy and pursuing its own priorities.
Enforcement against companies for breaching sanctions is on the rise
Enforcement against sanctions breaches has intensified globally, with the US and UK leading the charge.
In the UK, regulators stepped up their scrutiny on companies. Beyond the financial sector, the UK has also imposed a significant penalty on a law firm for Russia-related sanctions violations. Other notable actions include a £300,000 (US$401,427) fine against Markom Management by the UK Office of Financial Sanctions Implementation (OFSI) in March 2025. The HMRC’s largest-ever compound settlement for a Russia sanctions offence – £1.2 million (US$1.6 million) – against an unnamed exporter is another example of this trend.
Across the Atlantic, OFAC has issued 14 fines over the past year amounting to US$270 million, all levied against companies that breached US sanctions regimes. OFAC’s targeting of businesses is broadening across sectors and scaling up in severity, signalling that compliance failures carry increasingly high financial and reputational risks.
What’s on the horizon in 2026?
The sanctions enforcement landscape is set to evolve in 2026, as global conflicts continue and expand.
Several changes are expected in the UK. OFSI is considering substantial reforms to its enforcement practices for financial sanctions breaches. If implemented, these changes could increase penalties from £1 million (US$1.3 million) to £2 million (US$2.6 million) reduce discounts for voluntary disclosure and introduce new ways of resolving cases involving breaches.
In addition, from 28 January 2026, OFSI’s Consolidated List of Asset Freeze Targets is closing. It will be replaced by the UK Sanctions List, which from that date will be the only source for all UK sanctions designations. Businesses should begin to prepare for that change now, for instance by ensuring any sanction screening systems are moved to the new list.
In 2025, EU Member States were required to transpose Directive 2024/1226, which lays out bloc-wide minimum rules for prosecuting EU sanctions violations and aligns penalties for non-compliance by individuals and companies. But 18 Member States failed to meet the May 2025 deadline. In 2026, EU companies should expect stronger enforcement by Member States for sanctions violations.
With a peace plan for Ukraine currently in the works, global sanctions against Russia could also be subject to a gradual, phased easing. European leaders have insisted that decisions related to economic sanctions on Russia be taken into full consideration in any peace plan to end the war.
On the other side of the Atlantic, the US Supreme Court is considering a legal challenge to the administration’s use of the International Emergency Economic Powers Act 1977 to implement tariffs. The outcome of the case may significantly influence the Trump administration approach to trade policy, potentially by raising the importance of sanctions as means to influence global trading partners.