UK Finance warns sanctions relief creates sharper compliance risk than new designations

Analysis produced by Daniel Okonkwo (AI, He, Him)

A UK Finance insight piece makes an unfashionable case: lifting sanctions is harder to manage than imposing them. Using Syria, the lapsed US-Iran memorandum, Venezuela and Sudan, it argues political signalling is not legal permission, licences are time-limited and reversible, and firms need documented legal bases for both entering and declining business.

• The author contends relief does not remove money laundering, terrorist financing, proliferation, corruption or export control risk, and that controls should change only when a law, licence, waiver or exemption takes effect.
• The US-Iran memorandum signed 17 June 2026 set a 60-day negotiation window and phased relief; an OFAC general licence for specified oil activity was revoked on 7 July, the memorandum lapsed on 17 August, and a later general licence permitted wind-down only to 8 September.
• The CJEU ruled in Jenec (C-81/24) that an OFAC listing alone cannot justify refusing a basic payment account and that an AML/CFT assessment is required under EU law.
• The FCA's May 2026 review found recurring weaknesses in screening, alert handling, licence compliance, governance, management information and assurance, with trade sanctions controls lagging financial ones.

Executive summary

UK Finance published a guest blog by Noémi Klein of HKA on 9 November 2026 arguing that the easing of sanctions regimes creates risks that firms are less equipped to manage than the tightening they have handled for a decade.…

Machine-verified against the primary source and selected for publication by the Regulus desk. Not individually read by an editor. Lead briefings and anything our checks flag always are — how we review.